1. 1 Compliance Lessons from the Trenches Alan R. Yuspeh November 7, 2005

2. 2 First Observation The chief ethics and compliance officer, or ECO, should want to be seen as the leader of a business function in the Company and not as an internal police officer.

3. 3 Second Observation Relationships are critically important.

4. 4 Third Observation There is no room for ego in doing this job well.

5. 5 Fourth Observation Innovation is a challenge!

6. 6 Fifth Observation There must be individuals at each local business unit to deliver the ethics and compliance program.

7. 7 Sixth Observation There must be a system to routinely solicit and consider field input.

8. 8 Seventh Observation There must be an effective utilization of technical expertise.

9. 9 Eighth Observation Ensuring that all operational leadership is engaged is very difficult.

10. 10 Ninth Observation You need to have senior management who in a very intuitive way buy into this kind of effort.

11. 11 Tenth Observation There must be an appreciation of true ethical dilemmas faced by an organization and how they should be resolved.

12. 12 Compliance Lessons from the Trenches Alan R. Yuspeh November 7, 2005