Drop That Ledger! This Is the Compliance Officer

DAVID C. FARRELL held up a half-inch-thick document titled " Enron Code of Ethics 2000," and stared across a table at four colleagues sitting in a conference room at Sun Microsystems' campus-style office complex here in Silicon Valley.

"I wave this around at meetings to make a point," Mr. Farrell said. "It's not enough just to write a code of ethics. The management and the people who work at a company have to lead by example. We call it 'the tone at the top.' "

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