Joe Murphy (jemurphy5730@gmail.com) is a Senior Advisor at Compliance Strategists, SCCE’s Director of Public Policy, and Editor in Chief of CEP Magazine.
You already know that one purpose of a compliance and ethics program is to be able to convince a regulator or prosecutor that any violation was not a deliberate corporate act, but something that occurred despite your company’s best efforts to prevent it. (Of course, the prime objective is to prevent wrongdoing in the first place, but even so, violations can happen).