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Unpublished Paper
In Search of Effective Ethics & Compliance Programs
ExpressO (2014)
  • Maurice E Stucke, University of Tennessee

The U.S. Sentencing Commission’s Organizational Guidelines for over twenty years have offered firms a significant financial incentive to develop an ethical organizational culture. Nonetheless, corporate crime persists. Too many ethics programs remain ineffective. As this Article explores, the Guidelines' current approach is not working. The evidence, including sentencing data over the past twenty years, reveals that few firms have effective ethics and compliance programs. Nor is there much hope that the Guidelines' incentive will induce companies, after the economic crisis, to become more ethical. The problem is not attributable to three assumptions underlying the Guidelines. The empirical research, while still developing, suggests that compliance efforts can be effective, and that effective compliance is attainable. Instead this Article explores how the Guidelines’ extrinsic, incentive-based approach to compliance does not cure, and likely contributes to, the problem.

  • Organizational Guidelines,
  • corporate crime,
  • compliance,
  • ethics,
  • antitrust,
  • FCPA,
  • organizational culture,
  • intrinsic motivation,
  • behavioral economics
Publication Date
February 14, 2014
Citation Information
Maurice E Stucke. "In Search of Effective Ethics & Compliance Programs" ExpressO (2014)
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