2. Business Ethics: Ethics can be defined as standards or principles of conduct that govern the behavior of an individual or a group of individuals. Ethics are generally concerned with moral duties or questions of what is right and wrong. 3 levels of ethics Law – how society codifies its ethical standards Policies or guidelines – as defined by institutions or organizations Moral standards – subject to individual interpretation

3. Corporate Compliance Officers GENERAL SUMMARY The Chief Compliance Officer oversees the Corporate Compliance Program, functioning as an independent and objective body that reviews and evaluates compliance issues/concerns within the organization. The position ensures the Board of Directors, management and employees are in compliance with the rules and regulations of regulatory agencies, that company policies and procedures are being followed, and that behavior in the organization meets the company’s Standards of Conduct. The Corporate Compliance Office exists: As a channel of communication to receive and direct compliance issues to appropriate resources for investigation and resolution, and As a final internal resource with which concerned parties may communicate after other formal channels and resources have been exhausted.

4. GENERAL PURPOSE The Chief Compliance Officer acts as staff to the CEO and Board of Trustees’ Corporate Compliance Committee by monitoring and reporting results of the compliance/ethics efforts of the company and in providing guidance for the Board and senior management team on matters relating to compliance. The Chief Compliance Officer, together with the Corporate Compliance Committee, is authorized to implement all necessary actions to ensure achievement of the objectives of an effective compliance program.

5. Develops, initiates, maintains, and revises policies and procedures for the general operation of the Compliance Program and its related activities to prevent illegal, unethical, or improper conduct. Manages day- to-day operation of the Program. Develops and periodically reviews and updates Standards of Conduct to ensure continuing currency and relevance in providing guidance to management and employees.

6. Collaborates with other departments (e.g., Risk Management, Internal Audit, Employee Services, etc.) to direct compliance issues to appropriate existing channels for investigation and resolution. Consults with the Corporate attorney as needed to resolve difficult legal compliance issues.

7. Responds to alleged violations of rules, regulations, policies, procedures, and Standards of Conduct by evaluating or recommending the initiation of investigative procedures. Develops and oversees a system for uniform handling of such violations. Acts as an independent review and evaluation body to ensure that compliance Issues/concerns within the organization are being appropriately evaluated, investigated and resolved. Monitors, and as necessary, coordinates compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends.

8. Identifies potential areas of compliance vulnerability and risk; develops/implements corrective action plans for resolution of problematic issues, and provides general guidance on how to avoid or deal with similar situations in the future. Provides reports on a regular basis, and as directed or requested, to keep the Corporate Compliance Committee of the Board and senior management informed of the operation and progress of compliance efforts. Ensures proper reporting of violations or potential violations to duly authorized enforcement agencies as appropriate and/or required.

9. Establishes and provides direction and management of the compliance Hotline. Institutes and maintains an effective compliance communication program for the organization, including promoting (a) use of the Compliance Hotline; (b) heightened awareness of Standards of Conduct, and (c) understanding of new and existing compliance issues and related policies and procedures.

10. Works with the Human Resources Department and others as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees as well as ongoing training for all employees and managers. Monitors the performance of the Compliance Program and relates activities on a continuing basis, taking appropriate steps to improve its effectiveness.

11. Define your problem or issue. Write down all ideas for the solution to your problem Give each idea consideration and choose as a group the best solution to your problem.

12. Managing Ethics 1.Recognize that managing ethics is a process. Ethics is a matter of values and associated behaviors. Values are discerned through the process of ongoing reflection. Therefore, ethics programs may seem more process-oriented than most management practices. Ethics programs do produce deliverables, e.g., codes, policies and procedures, budget items, meeting minutes, authorization forms, newsletters, etc. However, the most important aspect from an ethics management program is the process of reflection and dialogue that produces these deliverables.

13. 2. The bottom line of an ethics program is accomplishing preferred behaviors in the workplace. As with any management practice, the most important outcome is behaviors preferred by the organization. The best of ethical values and intentions are relatively meaningless unless they generate fair and just behaviors in the workplace. That's why practices that generate lists of ethical values, or codes of ethics, must also generate policies, procedures and training that translate those values to appropriate behaviors.

14. 3. The best way to handle ethical dilemmas is to avoid their occurrence in the first place. That's why practices such as developing codes of ethics and codes of conduct are so important. Their development sensitizes employees to ethical considerations and minimize the chances of unethical behavior occurring in the first place.

15. 4. Integrate ethics management with other management practices. When developing personnel policies, reflect on what ethical values you'd like to be most prominent in the organization's culture and then design policies to produce these behaviors.

17. The hallmark of good supervision is effective delegation. Delegation is when supervisors give responsibility and authority to subordinates to complete a task, and let the subordinates figure out how the task can be accomplished. Effective delegation develops people who are ultimately more fulfilled and productive. Managers become more fulfilled and productive themselves as they learn to count on their staffs and are freed up to attend to more strategic issues.

18. Delegation is often very difficult for new supervisors, particularly if they have had to scramble to start the organization or start a major new product or service themselves. Many managers want to remain comfortable, making the same decisions they have always made. They believe they can do a better job themselves. Often, they don't want to risk giving authority to subordinates in case they fail and impair the organization.

19. 1. Delegate the whole task to one person This gives the person the responsibility and increases their motivation. 2. Select the right person Assess the skills and capabilities of subordinates and assign the task to the most appropriate one. 3. Clearly specify your preferred results Give information on what, why, when, who and where. You might leave the "how" to them. Write this information down. 4. Delegate responsibility and authority -- assign the task, not the method to accomplish it Let the subordinate complete the task in the manner they choose, as long as the results are what the supervisor specifies. Let the employee have strong input as to the completion date of the project. Note that you may not even know how to complete the task yourself -- this is often the case with higher levels of management. 5. Ask the employee to summarize back to you, their impressions of the project and the results you prefer

20. 6. Get ongoing non-intrusive feedback about progress on the project This is a good reason to continue to get weekly, written status reports from all direct reports. Reports should cover what they did last week, plan to do next week and any potential issues. Regular employee meetings provide this ongoing feedback, as well. 7. Maintain open lines of communication Don't hover over the subordinate, but sense what they're doing and support their checking in with you along the way. 8. If you're not satisfied with the progress, don't take the project back Continue to work with the employee and ensure they perceive the project as their responsibility. 9. Evaluate and reward performance Evaluate results more than methods. Address insufficient performance and reward successes.

22. Fostering teamwork is creating a work culture that values collaboration. In a teamwork environment, people understand and believe that thinking, planning, decisions and actions are better when done cooperatively. People recognize, and even assimilate, the belief that “none of us is as good as all of us.” (High Five) culture(High Five)

23. Create a Culture of Teamwork Executive leaders communicate the clear expectation that teamwork and collaboration are expected. No one completely owns a work area or process all by himself. People who own work processes and positions are open and receptive to ideas and input from others on the team. Executives model teamwork in their interaction with each other and the rest of the organization. They maintain teamwork even when things are going wrong and the temptation is to slip back into former team unfriendly behavior. The organization members talk about and identify the value of a teamwork culture.. If values are formally written and shared, teamwork is one of the key five or six.

24. Teamwork is rewarded and recognized.. Compensation, bonuses, and rewards depend on collaborative practices as much as individual contribution and achievement.