As a leader in your organization, it is vital that you are familiar with the laws that regulate your industry. Sparked by the dramatic corporate and accounting scandals of Enron, Arthur Andersen, Adelphia, and WorldCom, the Sarbanes-Oxley Act was implemented in 2002 in an effort to restore confidence in the stock markets. Sarbanes-Oxley represents the most important securities legislation since the original federal securities laws of the 1930s as it increased governmental regulation and oversight of publicly traded companies and established protections for whistleblowers. The False Claims Act and the Dodd-Frank Wall Street Reform and Consumer Protection Act provide a financial incentive for those who blow the whistle to report fraudulent activity within their organization.

In this task, you will select and analyze an established company’s code of ethics, analyze how an employee would raise an ethical concern within an organization, and consider current laws with respect to whistle-blowers.


You are an experienced ethics officer who has recently been hired by an established company. You have been tasked with analyzing the company’s current code of ethics and identifying areas in need of improvement.


A.  Choose a company’s code of ethics from the Web Links section below and analyze that company’s code of ethics by doing the following:

1.  Analyze how well the chosen company’s code of ethics covers the topic of corporate social responsibility (CSR).

2.  Analyze how well the chosen company’s code of ethics covers the topic of compliance with legal mandates.

a.  Describe the ramifications for an organization when it is noncompliant with legal mandates.

b.  Describe two legal or ethical safeguards the chosen company has in place or could put in place to prevent illegal or unethical acts.

3.  Analyze how well the chosen company’s code of ethics facilitates the development of an ethical culture.

4.  Explain how an employee would raise an ethical concern in the chosen company and provide three resources available to employees to use when raising an ethical concern.

a.  Discuss which resource(s) you would most likely use to report an ethical concern.

B.  Develop a policy that instructs employees on how to address unethical conduct observed at work by doing the following:

1.  Discuss personal and organizational factors an employee would need to consider as a last resort before deciding to blow the whistle about unethical conduct observed at work.

2.  Describe the internal and external reporting steps an employee should follow if the employee decides to blow the whistle.

C.  Analyze the advantages and disadvantages of whistle-blowers receiving payment from the government based on one of the following laws:

•  False Claims Act 

•  Dodd–Frank Wall Street and Consumer Protection Act

D.  Analyze how the U.S. Sentencing Guidelines have changed the way organizations operate.

1.  Discuss three culpability factors that are used to determine fines under the U.S. Sentencing Guidelines.

Web Links

PepsiCo – COE

Wells Fargo – COE

Synnex – COE

Comcast – COE

British Petroleum – COE

Walmart – COE

Target – COE

Mayo Clinic – COE

Kaiser Permanente – COE

Oracle – COE

Deloitte – COE

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