Last week I had the privilege of hosting another Compliance Week editorial roundtable, this time co-hosted with Crowe Horwath in Dallas to talk about corporate ethics. We’ll have a complete article as usual on that discussion in an upcoming edition, but for now I’d like to share a few personal observations.

Where ethics functions come from. In the spirit of ethics, let’s start with some honesty: As much as we all stress our sincere desire to have a strong ethical culture, and how those cultures attract better employees, and lead to better performance, and so forth and so on—many companies still create an ethics function only when they’re facing the business end of a regulatory enforcement action. We went around the room asking roundtable participants when and why their companies created an ethics and compliance function, and a common response was, “Well, we had an incident…”