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Firms have exponentially increased their investment in the creation and implementation of ethics and compliance programs over the past fifteen years. The convergence of more robust corporate enforcement actions and more sophisticated industry standards and practices surrounding compliance efforts has created a booming compliance industry with commonly accepted standards and responsibilities. Within these efforts is a formal acknowledgment by the government, industry leaders, and academics that ethics has a role to play in helping to prevent misconduct within firms and that compliance without concern for ethics is insufficient. The reality, however, is that within firms’ efforts to implement effective ethics and compliance programs, compliance is king and ethics is something far less significant.

This Essay questions the wisdom of focusing on compliance without an equal focus on ethics. It challenges academics, industry leaders, compliance officers, and inside and external counsel to think critically about how firms might incorporate “More Meaningful Ethics” within their compliance efforts. This Essay argues that firms should implement specific and explicit ethical infrastructures within their compliance programs. In particular, this Essay suggests that firms commit to adopting policies and procedures that (i) protect the dignity of, (ii) promote the flourishing of, and (iii) advance the interests of the various stakeholders of firms as a baseline to be used for establishing the ethics components of their ethics and compliance programs.

Library of Congress Subject Headings

Corporate governance, Compliance, Business ethics, Organizational behavior--Moral and ethical aspects, Corporate culture--Moral and ethical aspects