Andrew Mitton

Here are a few high­lights from KPMG’s 2009 Fraud Report:

• Two-thirds of exec­u­tive reported that inad­e­quate inter­nal con­trols or com­pli­ance pro­grams at their orga­ni­za­tions enable fraud and mis­con­duct to go unchecked.
• Seventy-one per­cent reported that they were most con­cerned about a poten­tial loss of pub­lic trust result­ing from fraud and mis­con­duct in their organizations.
• The great­est room for improve­ment in their pro­grams is employee com­mu­ni­ca­tion and training.

Based on this report it seems the place to start is com­mu­ni­ca­tion.  With so many tools avail­able on the Inter­net, this should be easy to do.  But it all starts with the mes­sage, and the mes­sage comes from the Code of Con­duct.  The more effec­tive and inspir­ing the code, the bet­ter the mes­sage.  The bet­ter the mes­sage, the bet­ter the com­mu­ni­ca­tion.  Bet­ter com­mu­ni­ca­tion means that the pro­gram will ulti­mately be better.

Here’s another take: Bill Pawonka at Ethic­s­point says: what’s impor­tant is that your orga­ni­za­tion have a strong eth­i­cal cul­ture, a way to col­lect reports of mis­con­duct, and a sys­tem to con­sis­tently inves­ti­gate, doc­u­ment, resolve and ulti­mately ana­lyze each report.