The Sarbanes-Oxley Act was enacted to help fight corporate fraud. Public companies have spent untold millions to comply and hired compliance and ethics officers ostensibly to ensure that the law is adhered to.

Yet, somehow, at the end of the day, fraud is still here.

However comprehensive your code of ethics may be, and however many policies you have, realize this one truth: Your organization could be the next one to hit the headlines. Simply saying, “We strive for the highest ethical standards in our business,” and passing that off as your “tone at the top” will never deter a morally ...