The only way you can ensure compliance and show your good faith attitude in the face of potential legal action against the company is to provide ethics training that is provably effective.
Regarding financial rulings subsequent to Sarbanes-Oxley, here is what should be included:
- The proper legal response when employees report possible criminal behavior
- Proper control and retention of corporate documents
- The definition of conflict of interest
- What constitutes insider trading
- Appropriate behavior around gifts and entertainment
- Illegal anti-competitive practices
At the end of the day, the cost of training is minor compared to the cost of legal action.
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