Building a World-Class Compliance Program: Best Practices and Strategies for Success

Chapter 11. Recognizing Compliance Excellence: Premier, Inc. and Winning the Baldrige Award^[338]

"Compliance isn't something done by the external auditors who come in periodically and review progress. It should be done daily by everyone in the enterprise whose job responsibilities touch any of the defined internal controls."

—Sumner Blount, Director of Security Solutions, CA, Inc.

As the compliance and ethics profession evolves, the need to demonstrate how such efforts improve the performance of the organization becomes more important. Like any other component of a company's operation, a compliance department's contribution to that company's quality and continuing success likely will determine—or at least affect—that department's effectiveness and stature internally and externally.

Some have tried to establish the inherent value of an ethics and compliance program by focusing on the prevention of illegal activity and ethical lapses. While this is an important component of a compliance and ethics program, this is only part of the equation. This approach also presents considerable difficulty, as it requires the proof of a negative. Accumulating proof that a company would have violated a law or suffered a lapse in adherence to its ethical standards represents a difficult challenge at best. Even if one can demonstrate that the company avoided violating a law or other standard, demonstrating that the company's ethics and compliance program was the reason that the violation was avoided represents ...