An Integrated Approach to Creating A Culture of Integrity

Compliance and ethics professionals are trained to focus on regulatory matters and legalities. But for many, an additional challenge has–and will continue to be–creating an environment where employees and investors make sound decisions geared toward doing the right thing, even when the right thing is not the road more easily traveled. Maintaining a focus on values, however, especially during turbulent times, has now become an important part of any compliance professional’s training. While organizations have made significant strides to combat corruption in recent years, more support is needed from the public sector.

This is one of the many points recently highlighted in a FCPA Blogpost by Joe Murphy, Chair; and Emil Moschella, Executive Director, the Rutgers Center for Government Compliance and Ethics, who are calling on the Organization for Economic Cooperation and Development’s (OECD) Council to rethink its stance on Public Integrity and take into consideration some recommendations that will build and sustain cultures of integrity.

“A government cannot honestly claim it believes in an integrated approach to integrity and then turn around and attack the very efforts it claims it supports,” they wrote.

Based on Murphy’s and Moschella’s experience in the compliance and ethics field, they suggested that the OECD consider the following:

1. The Council should use the concept of a compliance and ethics (“C&E”) program, as widely applied globally, as a starting point and model;
2. The Council should consider using the OECD Working Group on Bribery’s Good Practice Guidance modified to address public integrity and public sector entities;
3. The Recommendation should include a model or models (examples) to illustrate how the suggestions in the Recommendation would work on a best practice basis;
4. The Council should include public international organizations, such as the OECD, in the scope of the Recommendation;
5. The Recommendation should call on the public sector to promote C&E in the private sector to protect public integrity;
6. The Council should advise states not to take actions that undercut C&E programs anywhere, whether in the private sector or the public sector;
7. The Council should form an ongoing working group to promote and implement this Recommendation; and
8. The Rutgers Center for Government Compliance and Ethics offers an important resource for development of public integrity programs.

Find out more here.