In today’s world of daily and instantaneously communicated risks, crises and scandals related to ethics and compliance—or what we call “E&C” risks—it is no longer simply desirable for companies to have an E&C risk-management program: It is a business necessity. Indeed, it is increasingly crucial to have an E&C risk-management system that is integrated with a company’s enterprise risk-management system.
At Bertelsmann AG, the €17.9 billion global media company, we have engaged in such a holistic risk assessment and management process for a variety of sound business and legal reasons. Indeed, we began to conduct E&C risk management in the United States years ago even before the 2004 revisions to the U.S. Federal Sentencing Guidelines, which made it a legal requirement for companies in the United States to conduct periodic E&C risk assessments.
