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TABLE OF CONTENTS

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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