¶ … ethical leadership problems that resulted in Columbia's misconduct. The company had a poor training program that could not possibly have communicated the need for ethical behavior. There was no commitment from the firm's executives to ethical behavior; many in fact were committed to unethical behavior. The corporate culture was focused on intimidation from the top, rather than on ethical behavior as taking precedence.
The current ethics program contains an ethical component and has strong leadership commitment from the top of the company. Another strength is that the new program includes an extensive training program. One glaring weakness is that the new program does not balance the needs of other stakeholders. The firm's profitability decline significantly as the company became myopic in its pursuit of improved ethics. Another weakness is that the chain of leadership is muddled, with far too many executives in charge of various components of the program.
The current program appears to satisfy all seven provisions of the Federal Sentencing Guidelines that will allow for lower sanctions. The program does not specifically address the provisions of SOX, however. The program focuses on building an ethical culture, but does not appear to specifically address fraud risk assessments, controls over fraud prevention or other SOX provisions.
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