Reference no: EM132217624
Code of Ethics and Business Conduct [To illustrate the concepts in this case study, the following scenario changes the facts provided in Case Study 1, “Auditing Entity-Level Controls,” where it was stated that SHR had a written code of conduct.] In the past, SHR has relied on a collection of individual policies to communicate its expectations regarding compliance with laws, regulations, and internal operating practices. The senior vice president – legal, who also is designated as SHR’s CCO, has determined that the company has grown to a size and operating complexity necessitating an integrated code of ethics and business conduct (the “code”). He has assembled a team consisting of personnel from the legal, human resources, and internal audit functions to develop this code. Scenario 1 Activities
1. Explain why it is important to include representatives from the legal, human resources, and internal audit functions in the development of the code. What other areas of the organization, if any, should also be consulted when developing the code?
2. Based on the background and case facts describing SHR Corporation’s business, identify the types of laws and regulations that the company is subject to and should consider for inclusion in the code.
3. Develop an outline for SHR’s code listing the sections that should be considered to create a robust, comprehensive code. There is no need to develop any of these sections; simply create the outline.
4. Describe ways for communicating the new code and providing the necessary training to employees and new hires.
5. There are other key elements to an effective compliance and ethics program.
Discuss the value of the following:
a. Annual certification of compliance.
b. Whistleblower hotline.
c. Escalation and investigation process.
d. Disciplinary action process.
e. Compliance program audits.
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