McKonly & Asbury Webinar - Business and Personal Ethics


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This presentations discusses personal and business ethics, perspectives, various approaches to ethics, and some key components of ethics application including the importance of communication. It then talks about the key components of an ethics program and what you should expect to find within an organization.

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  • Good afternoon and welcome to the Business Ethics Webinar. My name is Elaine Nissley and I am a Principal in the Assurance and Advisory segment at McKonly and Asbury. As you can see, I enjoy obtaining certifications including the certifications in Information Systems Audit, Project Management, Risk and Information Systems Controls and Risk Management Assurance. I have over twenty years experience in risk management, internal audit, internal controls assessments and project management. I am a volunteer instructor for the Institute of Internal Auditors, Adjunct Professor for the University of Phoenix where I teach MBA level management classes, and a frequent speaker on risk management, internal controls, internal audit and project management topics.
  • Risk management service provides internal audit out sourcing, performance audits, and Sarbanes Oxley compliance audits. Through these engagements we frequently perform governance assessments that include looking at the business ethics program, the ethics culture and assessing the soft governance controls which provide an ethical business environment. Today we will be discussing personal and business ethics and learning about different ethical perspectives and styles.
  • First I want to let you know that during this presentation, you will be taking a short quiz. Please make sure you have a piece of paper and a pen or pencil handy. How many of you remember GI Joe? At the end of his show he always provided a safety tip for children. You might see children in a room with smoke and they are rushing to the door. Suddenly GI Joe shows up and stops the children. He explains how to put a towel under the door to stop the smoke from coming in the room. He also teaches them to feel the door to see if it is hot. He then shows them how to leave the room via the window. In the end he says, “Now you know, and knowing is half the battle.” Today we are going to look at the definition of ethics. We will go through a short quiz that will help you to understand your ethical perspective. And as GI Joe says, “Knowing is Half the Battle.” We will learn traits of the various ethical perspectives and styles to raise our awareness, we will discuss an ethical approach to balance our ethical perspective and look at ethics in a more objective fashion. This knowledge will assist us in determining what steps to take to develop an ethical culture which will result in consistent ethical decisions throughout the organization. Some may also come to see how their ethical perspective aligns or does not align with their organization. It will help you to better understand the basis for ethical decisions made by your colleagues and management. From an audit perspective, we will look at some of the risks surrounding ethics and the types of controls organizations should have in place to safeguard the organization and guide the ethical decisions of management and staff.
  • On the lighter side (Read the cartoon) Does the end really justify the means? This is a clear example of the end justifies the means basis of ethics. Does anyone relate to this? What do you think of when you think about the end justifies the means ethics? What I think of is Enron, WorldCom, and numerous other financial disasters.
  • One of my favorite management gurus in Peter Drucker. The “Ethics of Prudence”, Drucker wrote, "does not spell out what "right" behavior is." It assumes, instead, "that what is wrong behavior is clear enough—and if there is any doubt, it is "questionable" and to be avoided." Drucker added that "by following prudence, everyone regardless of status becomes a leader" and remains so by "avoiding any act which would make one the kind of person one does not want to be, does not respect.“ Drucker also said, "I have learned more theology as a practicing management consultant than when I taught religion”. This, he explained, is because "management always deals with the nature of Man and (as all of us with any practical experience have learned), with Good and Evil as well.“ As we will learn today, people have varying definitions of good and evil. Therein lies our dilemma in trying to achieve consistent ethical decisions within an organization.
  • So what is ethics? There are many definitions for ethics. Here are just a few of them. Click Some associate ethics with conduct, click others with moral values. Do you think there is a difference between personal and business ethics? If yes, how do they differ? Solicit comments form audience Click personal ethics generally relate to morality and how others expect you to act in society. Click business ethics is commonly called the “tone at the top” it is the culture or corporate values and code of conduct adopted by an organization. One of the issues that people face is a misalignment between personal, and business ethics expectations. During this presentation, we will discuss ways to look at both personal and business ethics.
  • People have different ethical styles or perspectives. An individual’s response to an ethical dilemma will vary based upon their ethical perspective or ethical style. To truly understand ethics, one must spend some time understanding different ethical perspectives and your own ethical perspective or style. There are various tools available which will provide insight into your approach to ethical decision making. We do not have the time today to go through the more in-depth Williams Institute test to obtain information on which of the four ethical perspectives you use to approach your ethical decision making. I do have a shorter version which will provide you some insight into your ethical style. The first two ethical perspectives of character and obligation are aligned with the Justice style while the results and equity perspectives are aligned with the care style. After we go through the exercise of determining your ethical style, we will spend some time on defining the two ethical styles and the associated four ethical perspectives. One should keep in mind that nothing is ever black and white. Most people are not all one and none of the other, some are fairly balanced and others have definite leanings toward one perspective or style.
  • The following three slides will contain a series of nine questions. Please write the numbers one to nine on a piece of paper. For each of the nine questions write down the letter A or B which corresponds to your most immediate response to the question. I will read the questions on each slide providing you with about 1 minute for each slide.
  • One minute each slide
  • One minute
  • One minute
  • Now that you have completed the quiz. Please mark C or J beside each of your nine answers. For number one if you answered A then write down a C, if you answered B, write down a J. Continue through all nine questions marking a J or C based upon the chart on this slide. After you complete all 9, count the number of Cs and the number of Js. The more Js the more you rely upon justice. The more Cs the more you make your ethical decisions based upon care. Because Justice and Care appear so different, they may seem opposed to one another, but they’re actually complementary. In fact, your score probably shows you rely on each style to a greater or lesser degree. (Few people end up with a score of 9 to 0 or 0 to 9.) The more you can appreciate both approaches, the better you’ll be able to resolve ethical dilemmas and to understand and communicate with people who prefer the other style.
  • An ethic of justice is based on principles like justice, fairness, equality, or authority. People who prefer this style see ethical dilemmas as conflicts of rights that can be solved by the impartial application of some general principle. The advantage of this approach is that it looks at a problem logically and impartially. People with this style try to be objective and fair, hoping to make a decision according to some standard that’s higher than any specific individual’s interests. The disadvantage of this approach is that people who rely on it might lose sight of the immediate interests of particular individuals. They may unintentionally ride roughshod over the people around them in favor of some abstract ideal or policy. This style is more common for men than women.
  • On the other hand, an ethic of care is based on a sense of responsibility to reduce actual harm or suffering. People who prefer this style see moral dilemmas as conflicts of duties or responsibilities. They believe that solutions must be tailored to the special details of individual circumstances. They tend to feel constrained by policies that are supposed to be enforced without exception. The advantage of this approach is that it is responsive to immediate suffering and harm. The disadvantage is that, when carried to an extreme, this style can produce decisions that seem not simply subjective, but arbitrary. Some people will call this situational ethics because it appears that the ethical decisions are not consistent resulting in not being able to predict what a person’s ethical decision will be. This style is more common for women than men.
  • Let’s take a poll please send J or C. Does anyone have any questions related to the Justice vs Care styles of ethics. Are you beginning to understand why when people are faced with the same ethical choices, they will feel perfectly justified in making their decision which may vary from your own or may vary from the organization they work for? When it comes to the ethical style of an organization, you will find that the style of the senior management team is the style that is driven down through the organization. That is what is commonly called, “The Tone at the Top.” As I indicated earlier. The two styles of Justice and Care are a summary of the four perspectives of character, obligation, results and equity.
  • There are three steps in the ethical decision making process which we will cover today. They are awareness, articulation and application. Ethical awareness involves understanding ethical perspectives and styles. Not everyone approaches ethics from the same perspective nor do they apply the same principles or processes to the assessment of an ethical dilemma. Depending upon your perspective, you will react to an ethical dilemma differently. This explains why people do not always agree on the ethical approach to a dilemma. In other words, their styles differ. The four perspectives are character, obligation, results and equity. We will go into more detail on each of these perspectives shortly. Once a person understands the four ethical perspectives, they need to understand their personal perspective. It is helpful if they understand the perspective of the people they work with on a regular basis and also the organization they work for. Yes, organizations also have ethical perspectives, usually related to the CEO or top layer of the organization. Once you understand these difference you will appreciate the importance of how you communicate or articulate these differences to others. The last part we will cover is the application of ethical decision making. We will walk through a serious of questions to use in the ethical decision making process. This will help us to come to an ethical conclusion and we will also understand why not everyone is coming to the same ethical conclusion. I will ask each of you to work through a scenario and come to your ethical conclusion. We will then discuss the differences based upon the justice versus the care ethical style.
  • The ethical perspective, based on character or the Virtue Theory, believes that ethics should focus on ways to help people achieve moral excellence. When asked to judge if someone’s actions are ethical, the approach is to look beyond the person’s actions and look at their character. Uprightness, integrity, honor, justice, benevolence are some of the character traits considered important. So character is considered more important than actions. That is just complying with rules does not make someone an ethical person unless that person continually strives to be a morally good person. From a philosophical perspective, the character category aligns with the virtue ethical theory of philosophers such as Aristotle and Alasdair MacIntyre. “Virtue” is an old-fashioned word translating the Greek “arete,” which means “human excellence.” Virtue theorists have in mind an ethics of character. Also, the character traits or virtues must be beneficial. It is not because we admire these character traits that they are valuable; it is because they are beneficial—make for better lives—that we admire them. Look at the list of how people justify their ethical decisions based upon character. Good people do good things It is the right thing to do. It is only fair … Sound moral judgments … We need to protect our reputation The ethical style for the character category is that ethics relies on the ability of individuals to make sound moral judgments. You approach ethics by developing practical wisdom and sound judgment. You strive to be a person of wisdom and integrity. Some example of frustrations faced by those in the character category include: Although you strongly believe that mere compliance with organizational rules is not enough to build ethical character, you may work for an organization that relies heavily on a system of ethical rules and sanctions. You view this as an artificial ethical environment that is less than sincere. You are frustrated when ethical considerations appear to be tacked on to the real business of organizational decision making, like an afterthought. You believe this disregard for ethics is a negative reflection on the character of the decision makers.
  • People in the obligation category base their ethical perspective on a person’s duty or obligation to do what is morally right, that is principles that represent what rational people ought to morally do. These ethical principles must be 1) appropriate under any circumstance, 2) respectful of human dignity, 3) committed to promoting individual freedom an autonomy. To judge whether a person’s actions are ethical, they look at the intent behind the actions rather that focusing on the results. The end does NOT justify the means. The obligation category is most closely aligned with the deontological ethical theory by philosophers such as Immanuel Kant and John Rawls. This ethical style does not support social traditions and policies aimed at “the best interest of society as a whole” if any individual is denied the opportunities to which they are entitled as human being. You will advocate policies intended to ensure equal respect and opportunities for all. Moral decisions must reflect the free choice of individuals. Some examples of what frustrate you in addressing ethical dilemmas include: What you determine to be the right choice may not appear to be the most beneficial choice for your organization. The right choice does not always benefit the decisions maker. You believe we have a moral duty or obligation to do what is right which leaves little room for compromise when ethical principles are violated. You are frustrated to discover how various individuals define right and wrong, how conflicts are sometimes resolved in an organization setting, and who resolves them.
  • People in the results category base their ethical perspective on the results or consequences of your actions. The greatest good for the greatest number of people. To judge whether a person’s actions are ethical, they look for concrete evidence. People must not only talk the talk but also walk the walk. What really counts in reaching an ethical decision is the bottom line. Discussions about processes and principles is not as important as what is ultimately achieved for the overall good of society. The results category is most closely aligned with the utilitarian ethical theory by philosophers such as Jeremy Bentham and John Stuart Mill. This ethical style believes that everyone has the moral right to experience the good life. One way to measure the good life is to determine how satisfied the majority of the people in our society seem to be. If most people are unhappy, something is morally wrong and needs to be fixed. An approach may be to develop rules of ethical conduct for people to follow along with sanctions with the objective of achieving what is best for society as a whole. Or you could improve overall satisfaction by creating a more pleasant environment in which people enjoy learning and working together for the betterment of society. Some examples of what frustrate you in addressing ethical dilemmas include: The wide variety of competing views regarding what is good for society as a whole and the process used to determine whose view prevails. People who cling to the idealistic notion of protecting the interests of some minority of the population which may stand in the way of achieving the good life for the majority. People you work with who do not share your ethical approach, thereby interfering with your ability to achieve the desired results.
  • People in the equity category base their ethical perspective on a concern for the instability of knowledge, the uncertainty of human judgment and the lack of individual who can truly qualify as experts in the discernment of what is right and wrong. Education does not provide all of the answers. The only reasonable guide to action is pragmatism, and practical day to day experience. There is a distrust of attempts to define universal principles and moral values which is based upon a distrust of the motives of the individuals involved. As long as decision makers disregard the cultures and lives of minorities, any discussion that suggests a unity of belief is absurd. The results category is most closely aligned with the postmodern ethical theory by philosophers such as Michael Foucault and David Harvey. This ethical style believes there are no absolute standards of right and wrong. With new knowledge and different circumstances an individual’s beliefs and values may change. The approach to ethics is to challenge all attempts to plan ideal social orders rationally and to distrust institutionalized codes of ethics. (I would say that results is probably not a good category for examiners or accountants since what our profession demands is adherence to an ethical code of conduct). Some examples of what frustrate you in addressing ethical dilemmas include: In periods of crisis or chaos within your organization, short0term benefits and image frequently triumph over ethics as the primary concern. Without the structure of established standards of right and wrong, it may be difficult to justify your ethical decisions to others. Consensus becomes an arduous task. People you work with may not acknowledge the complexity of the worlds as you see it and tend toward recommending highly simplified solutions that appear to be little more than window dressing.
  • Which category did you fall into? Justice or Care? Look at the definitions and what we discussed. Someone with the Justice ethics style, do you see how your actions align with Justice, Character and Obligation? Provide some examples. Someone with the Care ethics style, do you see how your actions align with Care, Results and Equity? Most people are a combination versus all justice or care. As we go through the remainder of the discussion, keep in mind your style and how you may react based upon your style and why your ethical decision may vary from others.
  • The experts say that 80 up to as high as 94 percent of communication is nonverbal. This applies to ethics in a big way. A persons action convey a message about their ethics whether intended or no. Ten Basics of Ethical Communication Seek to “elicit the best” in communications and interactions with other group members. Listen when others speak. Speak non-judgmentally. Speak from your own experience and perspective, expressing your own thoughts, needs, and feelings. Seek to understand others (rather than to be “right” or “more ethical than thou”). Avoid speaking for others, for example by characterizing what others have said without checking your understanding, or by universalizing your opinions, beliefs, values, and conclusions. Manage your own personal boundaries: share only what you are comfortable sharing. Respect the personal boundaries of others. Avoid interrupting and side conversations. Make sure that everyone has time to speak, that all members have relatively equal “air time” if they want it.
  • When it comes to ethics, sitting on the fence is not an option. Also, an ethical decision is not someone else’s opinion but your opinion. When faced with an ethical dilemma, what are some actions you, as an individual can take to arrive at a decision? In the following slides we will cover some questions that you can apply to a situation. These questions are the types of tools one would expect to find in ethics training provided by an organization to arm the employees with the tools needed to make ethical decisions.
  • Think about the ethical perspectives of Justice versus Care. In what ways do you think the answers to these questions would differ between a person with a justice versus a care perspective. Justice – society Care - individuals
  • You are the only accountant employed by a small manufacturing firm suffering an economic downturn. You know your employer is going to ask the bank for an additional loan so that the firm can continue to pay its bills. Unfortunately, the financial statements for the year will not show good results, and your best guess is that the bank will not approve a loan on the basis of the financial information you will present. Your boss approaches you in early January, before you have closed the books for the preceding year, and suggests you might “improve” the company’s financial statements by treating the sales made at the beginning of January as if they were made in December. He says you can cover up the trail so that auditors will not discover the discrepancy. You know this step is against the professional rules of the Financial Accounting Standards Board (FASB), and you argue with your boss about it. He tells you that without the bank loan, the business is likely to close. That means you and everyone else in the firm will be out of a job. You believe he’s probably right, and in the current economic downturn it will be tough to find a new job. What are your alternatives? What are the likely consequences of each? What will you do? As for feedback from Justice and one from Care.
  • Persons and businesses face risks related to unethical behavior. I have listed a few major risks. Can anyone think of additional risks? Discuss With the mitigation for these types of risks being ethical decisions and ethical behavior, it is important that organizations foster and grow an ethical culture so they have some assurance that the ethical behavior of the employees is in line with the organizations ethics. Of course where the organization’s ethics could result in these types of risks, then growing a like culture may not reduce the risk for the organization. We will move ahead based upon the premise that decisions and behaviors that model the organization's ethical values will not result in any of the above risks. So how does an organization foster and grow and ethical culture?
  • An organization must be deliberative in their actions to build and sustain a corporate ethical culture. It begins with understanding ethical perspectives and styles and deciding in which camp the organization chooses to reside. Will they be more justice or care focused? Will their perspective be based upon character, obligation, results, equity or a combination of these perspectives? The organization must develop mission, vision and value statements which support their ethical perspective. Senior management must have their personal ethics aligned with the ethical perspective and style. The expectations must be written into policies and procedures and lived ouy daily by the organization’s management. The employees must be trained using examples of ethical dilemmas along with solutions which align with the ethical perspective and culture. Key to all good controls is the vigilance and monitoring of management and opportunities for employees to question actions or just to ask and verify they are making the right decision before making a decision they may regret.
  • It is not enough to have processes in place to train people and to have a means to recognize and report suspected unethical conduct. The organization also needs to have processes in place to respond appropriately to reports of suspected unethical conduct. Ideally there is an ethics committee which will oversee any investigations and insist upon determining the root cause of the issue, not just addressing the symptom and not solving the issue at the core. The ethics committee must have sufficient authority to adequately conduct an investigation and obtain cooperation in implementing the corrective actions. Reaction is good but there needs to be proactive measures as well. Things like background checks and effective systems of internal controls can be great deterrents to unethical conduct.
  • The hallmarks of a good business ethics program provide controls over all three sides of the fraud triangle. Internal controls - The organization should have a good system of internal controls which limits the opportunity for intentional or unintentional unethical behavior. Ethics/compliance Program - Educate employees on what is considered unethical conduct and make them aware of the negative consequences of participating in unethical behavior. Make it clear that turning your back on unethical conduct and not reporting it is considered participation. Educate employees that it is their duty to report unethical behavior. Make reporting easy and make sure employees know how to report suspected unethical conduct. Incentives – Make sure that corporate incentive programs do not reward employees for participating in unethical behavior. Fraud – Opportunity – Rationalization - Motive
  • McKonly & Asbury Webinar - Business and Personal Ethics

    1. 1. Business EthicsElaine Nissley, MBA, CISA, PMP, CRISC, CRMA Principal, McKonly & Asbury 1
    2. 2. Risk Management Services Risk and Internal Controls Assessments Internal Audit Outsourcing and Co- sourcing Information Technology Audits and Control Assessments Data Analysis Service Organization Controls Reports Performance Audits 2
    3. 3. Agenda What is Ethics  Definition  Awareness  Approach  Application Risks and Controls  Risk Identification  Controls 3
    4. 4. 4
    5. 5. “avoiding any actwhich wouldmake one thekind of personone does notwant to be, doesnot respect.”Peter Drucker 5
    6. 6. What is Ethics?Definition A set of principles of right conduct. A theory or a system of moral values. “Personal Ethics” General expectations of any person in any society, acting in any capacity (morality) “Business Ethics” Set of corporate values and codes/principles. 6
    7. 7. What is Ethics?Perspective StyleCHARACTER JusticeOBLIGATIONRESULTS CareEQUITY 7
    8. 8. What is your ethics style? Complete the following quiz Answer the nine questions Grade your paper On which side do you fall? Justice – J score Care – C score 8
    9. 9. What is your ethics style?1. Which is worse? a. Hurting someone’s feelings by telling the truth. b. Telling a lie and protecting someone’s feelings.2. Which is the worse mistake? a. To make exceptions too freely. b. To apply rules too rigidly.3. Which is worse to be? a. Unmerciful. b. Unfair. 9
    10. 10. What is your ethics style?4. Which is worse? a. Stealing something valuable from someone for no reason. b. Breaking a promise to a friend for no reason.4. Which is it better to be? a. Just and unfair. b. Sympathetic and feeling.4. Which is worse? a. Not helping someone in trouble. b. Being unfair to someone by playing favorites. 10
    11. 11. What is your ethics style?7. In making a decision you rely more on? a. Hard facts. b. Personal feelings and intuition.7. Your boss orders you to do something that will hurt someone. If you carry out the order, have you actually done anything wrong? a. Yes. b. No7. Which is more important in determining whether an action is right or wrong? a. Whether anyone actually gets hurt. b. Whether a rule, law, commandment, or moral principle is broken. 11
    12. 12. What is your ethics style?Score your results The higher your J 1. A _ C; B _ J score, the more you 2. A _ J; B _ C rely on an ethic of 3. A _ C; B _ J justice. The higher 4. A _ J; B _ C your C score, the 5. A _ J; B _ C more you prefer an 6. A _ C; B _ J ethic of care. Neither 7. A _ J; B _ C style is better than 8. A _ C; B _ J the other, but they 9. A _ C; B _ J are different.Source: Thomas I. White, Discovering Philosophy—Brief Edition, 1e, © Copyright 1996. 12
    13. 13. Justice  Justice  Fairness/Equality  Authority  Roughshod  Men 13
    14. 14. Care  Reduce harm or suffering  Individual circumstances  Arbitrary  Women 14
    15. 15. Ethical Style 15
    16. 16. Ethical Perspective  Awareness  Perspective & Style  Principles & Processes  Articulation  Understanding  Communication  Application  Shared Decision Making 16
    17. 17. Awareness  Good people do good things.  It is the right thing to do.  It is only fair …  Sound moral judgments …  We need to protect our reputation … 17
    18. 18. Awareness  We owe it to them  We have a duty to  They deserve better …  They have a right to …  We have a moral obligation to … 18
    19. 19. Awareness  We need to focus on the bottom line  The best approach is a systemic approach  Keep the big picture in mind  Remember why we’re here 19
    20. 20. Awareness  Let’s be practical  We need to hear from the powerless  Diversity is important  We need to work to change bad rules 20
    21. 21. What is your ethics style? Justice CareCharacter/Obligation Results/Equity  Fairness  Responsibility to  Equality reduce harm or suffering  Authority  Dislike rules  Logical  Work to change  Impartial bad rules 21
    22. 22. Articulation/Communication  Listen when others speak.  Speak non-judgmentally.  Express your own thoughts, needs and feelings.  Seek to understand others.  Avoid speaking for others.  Manage personal and respect others boundaries.  Make sure everyone has time to speak. 22
    23. 23. Application  We cannot remain value neutral  We all believe there are right and wrong answers to ethical decisions  We may not all arrive at the same answer  No easy shortcut to ethical decision making  Must answer all of the questions 23
    24. 24. ApplicationWho will be affected by my decision?  Who are the people most immediately impacted?  Who else, not so obvious, will be impacted?  Who strongly supports an outcome? Why?  Who might have a strong opinion yet lacks the power, money, or status to be heard?  Who is affected in the short term, in the long- term?  Does my decision impact my family and friends? What do they think?  What do other stakeholders say? 24
    25. 25. ApplicationWhat would be the impact of my decision?  Have I compared a variety of alternatives?  How would different decisions affect impacted stakeholders?  Have I gotten input from all stakeholders?  What evidence exists to support my conclusions regarding the impact of various decisions?  Have I tailored my fact finding to fit some preconceived result or desired outcome due to my preferences? 25
    26. 26. ApplicationWhat ethical perspective is reflected by my decision?  What do I believe is the best ethical decision in this case?  What core belief, character, obligation, results, equity, underlies my decision and alternatives I considered?  Are there other factors that influenced my decision?  Pressure from above or peers?  Interest groups?  Personal financial gain?  Chance to get ahead?  Limited information or convenience?  Threats? 26
    27. 27. ApplicationCan I justify my decision on ethical grounds?  Is my decision fair to all involved? What is my ethical basis used to determine fairness?  Do I feel comfortable or frustrated with my decision?  If I were on the receiving end, would I feel like I was treated fairly?  Would I feel comfortable having my decision as front page news? Can I justify it during and interview?  What would be my ethical justification and rationalization?  Would I use this case to teach young people about making ethical decisions? 27
    28. 28. Ethical Dilemma You are an accountant for a firm suffering an economic downturn. Financial statements will not support a bank loan request. Early January prior to closing the books, the boss requests you move January sales revenue into December. You disagree with your boss but he says without the bank loan, the business is likely to close. The current economic downturn would make it difficult for you and the other employees to find a job. What are your alternatives? What are the likely consequences of each? What will you do? 28
    29. 29. Risks Loss of reputation Loss of customers Unhappy employees Loss of revenue Legal action Regulatory sanctions 29
    30. 30. Ethical Culture Corporate Culture  Mission, Vision and Value Statements Aligned  Senior Management on the Bandwagon Policies and Procedures Training Monitoring  Management is Vigilant  Management is Approachable  Anonymous Reporting 30
    31. 31. Ethical Culture Respond to incidents  Policy/Procedure to report  Ethics Committee Takes steps to prevent repeat incidents  Root Cause Analysis  Reduce Control Gaps Assess risk of criminal conduct  Background Checks Takes steps to mitigate high risks  Effective System of Internal Controls 31
    32. 32. IN SHORT Limit Opportunity Instill Fear of Consequences Eliminate Corporate Motivation 32
    33. 33. Questions?Elaine Nissley, MBA, CISA, PMP, CRISC, CRMA Principal, McKonly & Asbury 33