Erica Salmon Byrne (firstname.lastname@example.org) is the Executive Vice President of The Ethisphere Institute.
Late last year, the National Association of Corporate Directors released a blue-ribbon report titled Culture as a Corporate Asset. With the input of a diverse group of directors, they made ten recommendations on how a director should approach this topic; I am going to focus on two that have the greatest intersection with the ethics and compliance program, but the full report is worthy of your time.
First, they recommend that active monitoring of the culture be positioned as a full-board responsibility, with specific oversight activities housed in committees as appropriate (and documentation of that delegation). Second, they recommend that directors assess whether officers in key risk-management, compliance, and internal-control roles are well-positioned within management and in relationship to the board to support an appropriate culture.