“There is a hostile environment from regulators and the courts for senior management now,” said Darcy, president of the Center for Integrity in Pound Ridge, N.Y. “The risks have never been greater.” Further, he noted, “the extent to which we don't self-regulate, we get re-regulated.”

So how does a company get its employees to self-regulate? Hire the right employees and create a culture where people do the right thing. A necessary element is a code of ethics. Darcy shared a sample code currently being used by the meeting department of an anonymous financial services company (“ABC Financial.”) It begins with a prose paragraph that leads into the actual code, which reads in part: “Ethical conduct is the responsibility of all who work for, or act on behalf of, ABC Financial. Due to the nature of the work, the conference and meeting support staff are faced with making ethical decisions on a daily basis. Doing the right thing may not always be clear and we may need guidance in making the right decisions. These guidelines will serve as the basis for making decisions. Additional resources available include the ABC Policies and Principles Manual, the Employee Handbook, and ABC Ethics Policy.”

ABC Financial Code of Ethics:

• Adhere to the [organizational] “Code of Conduct.”

• In line with Company policy, avoid conflicts of interest by not accepting gifts, payments, fees, services, discounts, or other favors that would, or might appear to, improperly influence actions or decisions.

• Avoid actions which are or could be perceived as a conflict of interest or for individual gain.

• Refrain from using site inspections as personal vacations.

• Avoid participation in familiarization trips (“fams”).

• Respect the legal and contractual rights of all parties and honor all written and oral agreements.

• Honestly represent and act within your area of competency and authority without exaggeration, misrepresentation, or concealment.

• Do not disclose or provide access to confidential information received verbally or in written communication.

• All concessions earned from vendor agreements must be used for the Company's gain. For example, complimentary airline tickets awarded are to be used for business travel only.

• Staff members' participation on vendor boards or advisory groups is permitted with management approval, with the host company assuming all related costs.

Darcy pointed out the value of the prose paragraph leading into the actual code in this sample. By acknowledging that “doing the right thing” isn't always clear, the company encourages its employees to look for guidance. “Ethics is about progress, not perfection,” he said.

Darcy also commended ICPA for having a formal code of ethics. You can find it at www.icpanet.com.