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Compliance and Ethics Programs: Passivity Is Passe
Corporate compliance and ethics programs have matured significantly from their humble beginnings. Since they appeared in the 70s in response to government investigations of overseas bribery in the aerospace, defense and armaments industries, leading to enactment of the Foreign Corrupt Practices Act, compliance programs have spread into most, if not all, other industries. Moreover, compliance programs have received official 'endorsement' by the government through the Sentencing Guidelines for Organizational Defendants (Sentencing Guidelines), which appeared in their original form in 1991 as Chapter 8 of the Federal Sentencing Guideline Manual.
The adoption of corporate compliance and ethics programs throughout many industries led to the establishment of the Ethics Officer Association (EOA) in 1992 as 'a professional association for ethics officers and the organizations for which they work, that provides for sharing of ideas and best practices, continuing education and professional development.' From its 12 founding members, EOA has grown to over 1000.
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