Chapter 4: Measuring Effectiveness

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Defining Effectiveness: Anatomy of an Ineffective Compliance and Ethics Program

Much has been written regarding compliance and ethics program “effectiveness” as part of a collective effort to define what an effective compliance and ethics program actually looks like. Of course, various textbook academic definitions exist: the extent to which a compliance and ethics program or activity achieves its intended purpose; a measure of the accuracy or success of technique when carried out in an identified environment. However, these are not particularly helpful to organizations struggling first to understand compliance and ethics, then to pursue it effectively on a real, everyday operating level.

One of the reasons the reality of effectiveness is so elusive is that it is a relatively new, certainly complex, and in some cases, a subtle concept, which very few organizations have achieved. Furthermore, given that each organization is unique, using a boilerplate to create a program will not accomplish the compliance and ethics goal. This makes it difficult to recognize when a program is, in fact, effective.

From the viewpoint of a consultant, it becomes clear that although unique, the vast majority of organizations are not too terribly different from each other in terms of the elements it takes to achieve effective compliance and ethics—or the elements that are present when compliance and ethics is ineffective. Certainly the circumstances for implementation, personalities, and cultures vary; all of which affect the subtle “hows” but not necessarily the “ifs” of achieving effective compliance and ethics. Through organizational commitment and dedication to the principles of an active compliance and ethics plan, success is achievable regardless of the organization and its unique circumstances. By being able to recognize when a compliance and ethics element is ineffective, corrections can be made to improve compliance and ethics effectiveness.

Given that it is far more common in today’s environment for organizations to struggle with the essential elements of an effective compliance and ethics plan, this article will delve into the anatomy of an “ineffective” compliance and ethics program. By understanding where and how compliance and ethics programs break down, and how one weak aspect of a compliance and ethics program can affect all or many other aspects, we can begin to see more clearly how the intent of each element contributes to the overall results of effective compliance and ethics. Thereby, we also can avoid common compliance and ethics traps or pitfalls to which all organizations are vulnerable.

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