This article was republished with permission from Michael Volkov’s Corruption, Crime & Compliance.
When it comes to compliance, the best investment a company can make is to create and promote an ethical culture. Dollar for dollar, communicating this message is the money well spent.
A CEO has to commit time and effort to the program. If the CEO does not want to commit, the job will be much harder. A CEO who believes in the message of ethics and integrity can quickly turn his or her belief into a reality for a company.
A CCO can design effective compliance controls, implement them and then monitor the company. The controls are meant to reduce risk and ensure compliance. It takes time, money and resources to accomplish risk reduction.
A persuasive CEO who is committed to the issue can make ethics and integrity a part of a company’s fabric. A consistent message of ethics and integrity when repeated throughout a company will reduce risk, promote employee morale and improve corporate performance.
The investment in such an approach can be significant. It requires time and attention. In the end, it is “money” well spent. The return on this investment is incalculable but will pay significant dividends.
The challenge for the CCO is to identify as many communications avenues as possible to deliver the ethics and integrity message. A CEO has to repeat the message at every possible opportunity and cannot restrict the message to infrequent presentations or a canned video message before a compliance training program.
When a CEO embraces the message and delivers it with confidence and sincere commitment, it is a powerful force in a company. Senior managers and middle managers have to be part of the program. They have to repeat the same message, respond to different views in the company and promote the importance of ethics and compliance.
An ethics culture has to include a “speak up” message. Companies have to encourage individuals to raise potential problems in the company. A positive message for speaking up easily translates into proof of a culture of ethics and integrity.
A CEO has to deliver the “speak up” message and commit to responding positively to employee concerns. Without this basic commitment, employees will ignore ethics and integrity.
The value of an ethics and integrity message is incalculable. If successfully integrated into the company fabric, it is the most effective means to mitigate risks. Managers and employees who are involved in risky interactions will think twice before engaging in misconduct.
All the training in the world, all the elaborate internal controls and forms and approvals are insignificant in comparison to the value of a culture committed to ethics and integrity.
Michael Volkov is the CEO of The Volkov Law Group LLC, where he provides compliance, internal investigation and white collar defense services. He can be reached at 
