Enron had all of the elements usually found in comprehensive ethics and compliance programs: a Code of Ethics, a reporting system, as well as a training video on Vision and Values led by Ken Lay and Jeff Skilling. And while there was criminal activity, Enron did not seek out to hire felons. Rather, it was the mindset and culture of the company that brought out the worst in some top executives, and inaction and passivity on the part of many others.
Culture is the leading risk factor for compromising integrity and compliance in companies today. Yet many organizations are unable to implement a truly effective ethics and compliance program because they lack sufficient knowledge of how their culture can create vulnerabilities and risks. And without that knowledge, companies cannot measure progress towards meeting ethics and integrity goals.
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