Guest Author - Consuelo Herrera, CAMS, CFE
honesty is the best policy" is true today more than ever. It's not just lip service. Employee business ethics manuals from most scandalized corporations are likely to contain slogans touting its commitment to honesty and integrity at work. Claiming to be honest and have good business ethics in an employee manual is passé. You're either honest or not. Even if you haven't got caught yet, most people know who is and who isn't.
“Honesty” - Scrupulous with regard to telling the truth and acting without stealing, fraud or breach of laws.
“Integrity” - Steadfast principled adherence to the Code of Business Ethics.
For example, a company spells out what it expects from its employees and from its managers as follows:
All employees have the responsibility to:
Comply with all applicable laws and regulations, and raise any conflicts between laws/regulations and the Code of Business Ethics or other policies and practices.
Understand the Code and all other requirements for their job.
Raise questions or concerns regarding business conduct and report any suspected violations of the law, regulations, the Code, other company policy or any health and safety issue.
You are encouraged in the first instance to make reports to your immediate manager or your business’ senior executive, including the designated ethics or compliance officer. Alternatively, reports may be made through the Spectris Hotline.
Managers at all levels have the additional duties to:
Ensure that their staff (i) know about and understand this Code and other policies and procedures that relate to their job and (ii) demonstrate compliance with these standards.
Encourage employees to raise questions or concerns regarding business conduct.
Address employees’ questions and concerns in a timely manner, and when unsure of how to respond, seek guidance.
Operating company Presidents/Managing Directors and their leadership teams are required to:
Make available to all employees this Code of Business Ethics and additional policies and procedures with which they are expected to comply.
Provide sufficient ways for employees to raise questions or concerns about business conduct.
Demonstrate the company’s values and a commitment to responsible business conduct in all of their actions.
Shades of gray
Sometimes making the right ethical decision is clear-cut and obvious. There are policies that need to be followed and rules and regulations that require compliance. But there are often many more situations that are not so easy to decide. It is the ambiguous issues where manager and employee engagement can be particularly effective.
Standards and principles are set forth in this document are intended to serve as guidelines applicable to the investigative efforts of criminal investigators working for the Offices of Inspector General (OIGs) affiliated with the President's Council on Integrity and Efficiency and the Executive Council on Integrity and Efficiency. While it is recognized that members of the OIG community are widely diverse in their missions and day-to-day operations, certain standards are applicable to any investigative organization. The standards outlined herein are comprehensive and relevant to a full range of government investigations, including all forms of misdemeanors and felonies (i.e., fraud, corruption, violence, property, narcotics, cyber, and white-collar crime), background and security inquiries, whistleblower issues, research misconduct issues, administrative and programmatic matters, and special investigations requested by any appropriate authority.
This booklet outlines two types of investigative standards—General and Qualitative. General Standards apply to investigators and the organizational environments in which they perform. They address the "need for" criteria and apply to all investigative activities from complaint processing, to gathering and analyzing evidence, to reporting investigative functions and processes with regard to investigations. Qualitative Standards address the "how to" criteria in general terms and include such areas as planning, conducting interviews, reporting investigative results, and related activities.
The Quality Standards for Investigations outlines goals that organizations must aggressively and actively strive to achieve. It is not intended, however, to serve as a detailed investigative handbook, with specific statutory or other legal requirements. Rather, each OIG should develop and issue an investigations manual to address implementation of these standards, as well as investigative procedures tailored to its particular mission and investigative discipline. How agencies implement them depends upon the unique circumstances of the respective department or agency.