Our Approach

VCU's Ethics and Compliance Program is based on integrity—the quality of consistently adhering to all of the Ethical Standards even when confronted by personal, professional, social or economic pressures. This includes considering how others may perceive our actions and whether these decisions align with our core values, vision and mission

Values-based Programs     vs.     Traditional Thinking

Use incentives to change behavior Punitive measures to change behavior
Find core risk areas of a law Have academic debates about a law
Help people understand the spirit of law Discuss negative side effects of the law
Gather all the facts for leadership Gather information to defend
Compliance protects the bottom line Compliance is a cost center
Operational discussions Academic discussions
Use all elements of compliance Just tell people to do the right thing
Find and fix a problem Find and pass off problem
Audit affected areas Don’t turn over the rock
Root cause analysis of a mistake Make excuses and blame others
This is a lesson we can learn from We admit no wrongdoing
Help operations to find another way Just say no
Stand ground on important issues Go along and get along
Interest in preventing violations Interest in discounting enforcement
Independent and unbiased Defensive and conflicted
Correct serious problem Worried about next promotion
Investigate allegation Question complainant’s motives
Whistleblower may have something Whistleblowers are whiners
Study and follow existing laws Go to DC to get laws changed
Build ethical culture Assume everyone is ethical
Education helps prevent problems Education takes away from operations
Monitor compliance My people would never do such a thing
Discipline equally amongst all levels She/he is too important to discipline
Building trust increases business You have to cheat to increases business
Determine right thing to do Pick a side and fight
Is this the right thing to do? Can we defend it in court?
Ethical culture = trust/growth/revenue Ethics training is a waste of time
Study recent relevant settlements Discount recent settlements
Study enforcement guidance Belittle regulators/enforcement
Practical Theoretical
Face the facts Rationalize doing nothing
Learn from competitors mistakes Discount others as bad players

Source: Roy Snell, roy.snell@corporatecompliance.org