PREFACE & ACKNOWLEDGMENTS 7
INTRODUCTION 9
CHAPTER 1
Risk Assessments 13
CHAPTER 2
Creating an Ethics and Compliance Office 29
CHAPTER 3
Oversight by the Board and Senior Management 43
CHAPTER 4
Codes of Conduct 59
CHAPTER 5
Providing Ethical Advice and Receiving Allegations 77
CHAPTER 6
Internal Investigations 95
CHAPTER 7
Rewards and Discipline 111
CHAPTER 8
Communications and Training 125
CHAPTER 9
Employee Screening 141
CHAPTER 10
Program Assessment and Evaluation 155
CONCLUSION
Looking Forward: Where Are Ethics and Compliance Heading? 163
BIBLIOGRAPHY 175
ABOUT THE ECOA, THE ECOA FOUNDATION, AND THIS BOOK 180
INDEX 181
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