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 onโ€”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, โ€œWell, we had an incidentโ€ฆโ€