Ten Steps to Designing a Comprehensive Ethics Program

by Josephson Institute on December 6, 2010

1.  DIAGNOSIS & EVALUATION. Develop and administer (preferably with an an independent agency such as the Josephson Institute) a company-wide survey to provide a foundation for the design of the program.

  • Organizational Values – What do employees, especially mangers, perceive as the stated and operational values of the organization based on formal documents, formal and informal training, reward systems
  • Organizational Conduct – What is the perception about the congruence of stated and operational values and the prevalence or frequency of questionable, improper or illegal conduct?
  • Personal Values – What are the personal attitudes, opinions and beliefs of individuals, especially managers, and how compatible are these with the stated or operational values?
  • Personal Conduct – How consistent is the personal conduct of individuals within the organization, especially managers, with their own values and those of the organization?

2.  STRATEGY DEVELOPMENT. Assign a small committee with the confidence of leadership the task of developing a strategy embracing the issues raised below.

  • Goals for Change – What changes are desirable and necessary in the operational values and behavior of the organization and individuals?
  • Stakes – Clarify the stakes; what are the potential risks and rewards relating to the desired changes?
  • Commitment – How committed is the leadership of the organization to accomplishing these changes?
  • Time Frame – What is the time frame in which meaningful changes must be accomplished?
  • Resources – What resources, expertise, credibility, personal and financial are needed to accomplish the goals in the required time?

3.  STANDARDS OF CONDUCT. Review and as necessary modify the company’s standards of conduct to assure relevancy, clarity, comprehensiveness. The code should be anchored to and each provision should reflect the company’s values.

  • Articulate organizational values
  • Provide guidelines for dealing with potential value conflicts
  • Standards for specific functional contexts
  • Mechanisms for dealing with improper conduct

4.  RECRUITING & HIRING. Integrate value and behavioral goals into recruiting and hiring process so new employees are:

  • Disposed to honor those goals
  • Clear as to the expectations of the organization

5.  EDUCATION & TRAINING. Educate new and veteran employees about organizational values and standards of conduct, principled reasoning and ethical decision making to:

  • Provide an understanding of the nature and reasons for the organization’s values and rules
  • Provide an Opportunity to question and challenge values for sincerity/practicality
  • Teach ethical decision making skills related to commonly encountered issues
  • The more specific and customized the training, the more effective it is likely to be


Integrate value and behavioral goals into:

  • Performance review process
  • Employee counseling
  • Promotion decisions

7.  SUPPORT SYSTEMS. Establish m

  • echanisms for allowing employees to get additional instruction, clarification and guidance on how to deal with issues concerning organizational values and standards of conduct


  • Process for reporting misconduct without fear of retaliation
  • Information learned through complaints and investigations should be fed back to managers and integrated into annual training programs and follow-up audits


  • Establish ongoing mechanism to audit actual behaviors to assure adherence to values

  • Isolate cases that require action or discipline
  • Deter improper conduct by creating likelihood that it will be discovered and appropriately sanctioned


  • Various methods of organizational communications should reinforce both commitment to ethical principles and the core values of the organization

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