Mark Ohringer, Executive Vice President, Global General Counsel and Corporate Secretary at Jones Lang LaSalle, discussed what it takes to develop the perfect ethics program during his presentation at the 2015 Chief Legal Officer Leadership Forum in Chicago on Sept. 30. In his presentation, “The Secret to the Perfect Ethics Program Is in a Bottega Veneta Handbag,” Ohringer pointed out that a strong culture and management that operates with integrity are key for an ideal ethics program.
According to Ohringer, understanding a manager’s approach to ethics enables an organization to study all aspects of an ethics program. Developing an ethics program that is effective yet inexpensive is important for many organizations, Ohringer said. As such, he noted that each organization must closely examine its culture and approach its ethics program with a broad perspective: “The way to go about this will differ from one organization to the next since each one has its own cultural, demographic and geographical attributes that must be taken into account. … In all cases you will need to honestly evaluate what will get you to the fundamental essence of cultural permeation as opposed to what you really don’t need because, relatively speaking, it’s real value to the organization will be less than the cost of producing it.”
In addition, Ohringer said an organization’s board of directors should be directly involved in the development of an ethics program. This program should apply to all members of an organization equally, Ohringer said: “Make your code of ethics apply equally to your board with particular reference to conflicts of interest and then don’t bend the rules. Make sure your board members are compensated at market rates, meaning not at the very high end. And make sure the compensation committee is providing compensation to executives that is clearly related to the company’s performance.”