Question

Please, I need help writing a memo to the CCO analyzing the survey results attached (strengths and weaknesses) to gain a better understanding of employees' perceptions of the company's compliance and ethics program.

Many aspects of a successful compliance and ethics program can be evidenced by documentation that supports the effectiveness of the program. However, like other entity-level controls (an effective code of ethics is considered an entity-level control), employee perceptions and buy-in may significantly influence the success of a compliance and ethics program. Unfortunately, there is little "audit trail" evidencing whether employees perceive the value and importance of a compliance program.
Code of Ethics and Business Conduct Survey Results Survey Question Survey Results 1. Iknow where to find SHR's code of ethics and business conduct - OStrongly Agree 58% DAgтee ONeutral/Uncertain ODisagree OStrongly Disagree 20% 60% 40% 2. Ibelieve the people I work with know where to find SHR's code of ethics and business conduct - 17% Istrongly Agree 60% DAgree 19% ONeutral/Uncertain ODisagree OStrongly Disagree 20% 40%

Requirements:

3) Where there are issues, what should be the appropriate actions to be taken. Maybe the possible root cause(s) of each issue when coming up with recommendations.

4) In addition to the survey, what other procedures internal audit may recommend be performed to provide the CCO information on the effectiveness of the company's compliance and ethics program.

Answer 1

Answer:

In a competitive business environment, it is imperative for any organisation to have a vigil to ensure that its competitive position is maintained and continuous trust should be there to improve upon its business so as to earn name, fame and in turn profit. Every organisation operates in an environment that is subject to constant change. Hence, unless an organisation adapts itself to the changing environment, success cannot be guaranteed.

In order to achieve the said objective every organisation maintains the following strictly

1. Code of Ethics
2. Code of Conduct

The above are required to be maintained by the employees of the organisation who are driving force of the organisation. In this regard please note the following

1. Code of Ethics – It is the principles the organisation adopts to be followed by all employees of the organisation. Normally, a good practice is to show the same in the notice board, written on a board and hanging on the wall which helps to remind every day what employee has to follow as a principle and it also helps Client to understand the core value and principles as well.
2. Code of Conduct – It is the professional practices to be followed by every employees of the organisation which includes maintaining proper and positive attitude towards the work as well as maintaining high level of behaviour which considered to be the most effective tool for enhancing the Client and Customer relationship. While on the subject it is also to be noted that in practical field this approaches also very much depended on the human relationship an employee could able to develop which normally emerges out of love and affection towards the organisation and the gradual disappearance of fear from the mind of employee about loosing of the job in a very critical situation. In other wards the best Code of Conduct can be evaluated from the ownership an employee has.

Considering the above facts let us now analysis the each of the survey results and the possible recommendation in my opinion which would be appropriate.

1. I know where to find SHR's code of ethics and business conduct –

1. It is apricated that the employee knows what is the principles of the organisation as well as his approach towards achieving the same. However, percentage wise it needs improvement.
2. Causes – Might be due to lack of clarity.
3. Recommendation – Code of ethics should be properly documented and displayed which should be easily accessible. Business Conduct should also be properly and clearly documented and properly circulated about its adoption and should not be allowed any rejection of it rather violation should be strictly monitored.

2. I believe the people I work with know where to find SHR's code of ethics and business conduct-

1. It needs improvement.
2. Causes – Co-workers are not sharing the details.
3. Recommendation - Make responsible the people to share with their co-worker about the requirement of the organisation what their having already with them

3. I know who to contact if I have any questions about SHR's code of ethics and business conduct

1. It needs improvement
2. Causes-Not properly guided about whom to contact.
3. Recommendation – Every employee should be introduced with the contact person

4. I believe the people I work with know who to contact if they have any questions about SHR's code of ethics and business conduct-

1. It needs improvement.
2. Causes- Co-workers are not sharing the details.

4. Recommendation – Make responsible the people to share with their co-worker about the details of the contact person and in case of need they should be proactive.

5. I believe the people I work with know who to contact if they have any questions about SHR's code of ethics and business conduct-

1. It needs improvement.
2. Causes- Co-workers are not sharing the details.
3. Recommendation – Make responsible the people to share with their co-worker about the details of the contact person and in case of need they should be proactive.

6. I believe the people I work with know who to contact if they have any questions about SHR's code of ethics and business conduct-

4. It needs improvement.
5. Causes- Co-workers are not sharing the details.
6. Recommendation – Make responsible the people to share with their co-worker about the details of the contact person and in case of need they should be proactive.

1. It needs improvement.
2. Causes- Help-line not properly informed.
3. Recommendation – Help-line should written on the notice bord as well as text message should be sent to their registered mobile no.

1. It needs improvement.
2. Causes- Co-workers are not sharing the details.
3. Recommendation – Make responsible the people to share with their co-worker about the details of the contact person and in case of need they should be proactive.

1. It needs slight improvement.

4. Causes- May be people are not interested to work.
5. Recommendation – Confidentiality of the employee should be maintained.

10

1. It needs improvement.
2. Causes- May be Co-workers are not sharing the details.
3. Recommendation – Make responsible the people to share with their co-worker about the details of the contact person and in case of need they should be proactive and confidentiality should be maintained.

11.

1. It needs improvement.
2. Causes- Reported problems are not investigated properly and effectively.
3. Recommendation – Assurance should be given and outcome of the investigation should be intimated to all.

12

1. It needs improvement.
2. Causes-Co-workers are not sure whether the reported problems will be investigated properly and effectively.

4. Recommendation – Assurance should be given and outcome of the investigation should be intimated to all.

13.

1. It needs improvement.
2. Causes- Mostly people out of fear do not want to report.
3. Recommendation – Assurance should be given and outcome of the investigation should be intimated to all. Confidentiality should be maintained and reward system should be implemented.

14

1. It needs proper attention so that it can be improved.

3. Causes-Co-workers are not sure whether the reported problems will be investigated properly and effectively and also out of fear they do not want to report.

4. Recommendation – Assurance should be given and outcome of the investigation should be intimated to all. Confidentiality should be maintained and reward system should be implemented.

15.

1. It is good to have the result. Minor corrections are required with the people who want to leave the organisation at least they should continue to follow it.

16

1. It needs proper attention so that it can be improved.

4. Causes-Co-workers are not cooperating.

2. Recommendation – All should be checked thoroughly, if required people should be transferred.

17.

1. It needs complete improvement.

5. Causes-Most likely people have not understood the requirements.
6. Recommendation – Proper training should be imparted in this regard.

18

1. It needs complete improvement.
2. Causes-Co-workers have not understood the requirements.
3. Recommendation – Proper training should be imparted in this regard to co-workers

19.

(i) It needs complete improvement.

2. Causes-Most likely people have not developed the sense of belonging and taking ownership
3. Recommendation – Proper training should be imparted in this regard.

20

1. It needs complete improvement.
2. Causes-Most likely Co-workers have not developed the sense of belonging and taking ownership have not understood the requirements.
3. Recommendation – Proper training should be imparted in this regard to co-worker

In my opinion the following should be followed for better internal control.

(a) Proper training.

(b) All should be given all documents with details to be followed.

(c) All should encouraged.

(d) Awarding system.

(e) Always have a vigil about its effectiveness.

(f) Conduct surprise check.