Program Investments

“A budget is more than just a series of numbers on a page; it is an embodiment of our values.”

—Barack Obama

2025 PROGRAM PREPARATION

Doing Business With Integrity Reduces Risks

Examples of business failures when controls are not in place…

No Chief Risk Officer for 8 months before the biggest bank failure since the 2008 financial crisis

Toxic workplace culture leading to boycotts, eventual sale of club

Backlash over third-party factory working conditions; $1.9 billion loss in value

Complete lack of management, governance, accounting, and information security controls

ETHICS & COMPLIANCE

The Value of Robust Programs and Practices

“Companies should feel empowered to do the right thing—to invest in compliance and culture, and to step up and own up when misconduct occurs. Companies that do so will welcome the announcements today. For those who don’t, however, our Department prosecutors will be empowered, too—to hold accountable those who don’t follow the law.”

Lisa O. Monaco

Deputy Attorney General, Department of Justice Remarks made about the September 15, 2022 memo outlining revisions to Corporate Criminal Enforcement Policies

RESOURCE PLANNING

Annual Compliance Budgets

Source: The Sphere EQ 2024 Data Year

Which component of an ethics and compliance program is often underfunded but essential?

Continuous employee education and training
Regular compliance audits and risk assessments
Up-to-date and accessible policy documentation
Resources for reporting and addressing ethical concerns

Staffing and Budgets

"Data Resources and Access – Do compliance and control personnel have sufficient direct or indirect access to relevant sources of data to allow for timely and effective monitoring and/or testing of policies, controls, and transactions? Do any impediments exist that limit access to relevant sources of data and, if so, what is the company doing to address the impediments?"

- U.S. DEPARTMENT OF JUSTICE CRIMINAL DIVISION EVALUATION OF CORPORATE COMPLIANCE PROGRAMS 

Source: U.S. Department of Justice, Criminal Division