STEP 4 – ACHIEVE CRIMINAL AND CIVIL RESOLUTION

Heaven and Hell suppose two distinct species of men, the good and the bad; but the greatest part of mankind float betwixt vice and virtue.

—David Hume

The fourth step in moving from crisis to transformation is achieving criminal and civil resolution. The is the last step of the Empowering Integrity process that is focused on remediating misconduct and getting a company out of the crisis it is currently in. Steps 57 institutionalize integrity and strengthen the company to help avoid future crises. As you read on, however, bear in mind the visual that appears in Part III, which shows how the various ‘steps’ intersect and overlap.

Completing Step 4 can take a long time and involves complex, multi-jurisdictional legal proceedings. When a company has been caught breaking the rules, regulators and prosecutors move in to gather the facts of the case, determine the pervasiveness of violations of law, decide what punitive action they deem appropriate, and then take action. This can take years because the wheels of justice turn slowly, especially when multiple regulators and prosecutors from various jurisdictions are involved. While this process is happening – largely outside the control of the company – the company seeking to emerge from crisis cannot simply wait passively for the outcome.

A successful outcome of seeking resolution with authorities depends on the cooperation and goodwill that the company has demonstrated in Steps 1 ...

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