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Over the last two years, few topics in the field of compliance and ethics have generated more interest, and provoked more questions and concerns, than the topic of corporate culture-and rightly so. Compliance and ethics officers have every reason to be concerned about the new emphasis on culture. Paul Fiorelli, in a recent article summarized the increasing number of regulations and guidelines that refer to ethics and corporate culture and that are now being used to hold corporations and individuals accountable. The SEC, Congress, regulators, the Sentencing Commission, the New York Stock Exchange, the Department of Justice, rating agencies and others have all weighed in on the topic. For examples, consider just three recent business news headlines: Every organization has an existing culture. For most, the good news is that their existing culture, while containing a few bad elements, is largely in good shape. The task, therefore, is not to create or invent a new culture, but to identify what exists, assess where improvements are needed, develop an action plan and implement it. This may seem obvious and yet the temptation may be strong to skip the preliminaries and jump right into action plans and implementation. Too many organizations assume they know what their culture is. Nor should you assume that your views or the views of senior management accurately describe the existing corporate culture.

 

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