Ethics Program Management Flashcards
7 cards from real CCEP practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 7 Ethics Program Management flashcards as text
A compliance officer discovers that the ethics hotline vendor has been logging caller metadata without authorization. What is the MOST appropriate immediate action?
Answer: Suspend hotline operations and notify the board audit committee
Suspending operations to stop ongoing harm and notifying the board audit committee ensures proper governance oversight of a serious breach affecting reporter confidentiality.
Which metric BEST measures the effectiveness of an ethics training program?
Answer: Reduction in reported misconduct over time
A reduction in reported misconduct over time is the most meaningful outcome metric because it reflects actual behavioral change rather than just participation.
Under the U.S. Sentencing Guidelines, which factor can REDUCE a fine for an organization convicted of a federal offense?
Answer: Self-reporting the offense to authorities before investigation
Self-reporting before a government investigation is a mitigating factor under the USSG that can significantly reduce organizational fines.
A compliance manager wants to conduct a speak-up culture assessment. Which tool is MOST appropriate?
Answer: Anonymous employee survey with validated questions
An anonymous validated survey captures candid perceptions across the organization without the social pressure that undermines other methods.
Which element of the DOJ's evaluation framework for compliance programs asks whether the program works 'in practice'?
Answer: Does it work in practice?
The DOJ's three-part test explicitly asks whether the compliance program 'works in practice,' focusing on operational effectiveness rather than paper existence.
A global company's ethics code prohibits facilitation payments, but a local manager argues they are legally permitted in the host country. How should the compliance officer respond?
Answer: Apply the stricter global policy and document the decision
A company's global ethics code establishes the minimum standard that supersedes local permissions, and the stricter policy should be enforced consistently.
What is the PRIMARY purpose of a conflict-of-interest disclosure process?
Answer: To identify and manage situations where personal interests may compromise professional judgment
Conflict-of-interest disclosure processes are designed to surface potential conflicts so they can be managed, not necessarily to prohibit all outside interests.