c. Step 3: MANAGERS and others must be
trained to consider the ethical implications of
all business decisions.
d. Step 4: AN ETHICS OFFICE must be set up.
i. WHISTLEBLOWERS (insiders who re-
port illegal or unethical behavior) must
feel protected from retaliation.
ii. The CORPORATE AND CRIMINAL
FRAUD ACCOUNTABILITY ACT (Sar-
banes-Oxley, 2002) contains protections
for corporate whistleblowers and the
Dodd–Frank Act includes a “bounty” for
whistleblowers if the information given
results in a successful enforcement ac-
tion.
e. Step 5: OUTSIDERS such as suppliers,
subcontractors, distributors, and customers
must be told about the ethics program.
f. Step 6: THE ETHICS CODE MUST BE EN-
FORCED.
i. If rules are broken, CONSEQUENCES
should follow quickly.
ii. ENFORCEMENT shows that the code is
serious and cannot be broken.
4. A company’s ethics code is worthless IF NOT
ENFORCED.
a. Enron’s management sent the message to
employees that unethical behavior would be
tolerated.