CCEP Ethics Program Management 3 — Questions and Answers
Question 1: An ethics officer is designing a new hotline system. Which feature is MOST critical to encouraging use?
- Integration with HR systems for faster resolution
- 24/7 availability in multiple languages with anonymity protection (Correct answer)
- Automated case routing to the accused's supervisor
- Mandatory follow-up calls to reporters within 24 hours
Correct answer: 24/7 availability in multiple languages with anonymity protection
Around-the-clock multilingual access with robust anonymity protection addresses the two primary barriers — accessibility and fear of retaliation — that deter reporting.
Question 2: Which of the following BEST describes 'tone at the top' in the context of an ethics program?
- The ethics officer setting compliance policies unilaterally
- Senior leadership visibly modeling and communicating ethical values (Correct answer)
- The board approving an annual ethics budget
- Publishing the code of conduct on the company website
Correct answer: Senior leadership visibly modeling and communicating ethical values
Tone at the top refers to senior leaders actively modeling ethical behavior and communicating its importance, which sets the cultural standard for the entire organization.
Question 3: A compliance risk assessment reveals high inherent risk in a newly acquired subsidiary. What should the compliance officer do FIRST?
- Shut down the subsidiary pending a full audit
- Apply the parent company's compliance controls and measure residual risk (Correct answer)
- Request a regulatory opinion on the subsidiary's practices
- Hire an outside law firm to conduct a privileged review
Correct answer: Apply the parent company's compliance controls and measure residual risk
Applying existing controls and measuring residual risk is the proper risk management response — it quantifies exposure after mitigation before deciding on further action.
Question 4: Under Sarbanes-Oxley Section 301, audit committees must establish procedures for what purpose?
- Approving executive compensation packages
- Receiving and handling complaints about accounting and auditing matters (Correct answer)
- Overseeing the compliance officer's annual performance review
- Certifying the accuracy of quarterly earnings reports
Correct answer: Receiving and handling complaints about accounting and auditing matters
SOX Section 301 requires audit committees to establish procedures for receiving, retaining, and handling complaints regarding accounting, internal controls, and auditing matters.
Question 5: Which approach to ethics training is MOST likely to produce lasting behavioral change?
- Annual one-hour online modules with a quiz at the end
- Scenario-based discussions facilitated by managers in team settings (Correct answer)
- Distributing the updated code of conduct via email
- Mandatory acknowledgment forms signed by all employees
Correct answer: Scenario-based discussions facilitated by managers in team settings
Scenario-based discussions in team settings engage employees in applying principles to realistic situations, which research shows produces more durable behavioral change than passive training.
Question 6: A company's compliance officer reports that 80% of substantiated investigations involve repeat business units. What does this MOST likely indicate?
- The hotline is working well in those units
- There is a systemic culture or control failure in those units requiring targeted intervention (Correct answer)
- Employees in those units are more dishonest than average
- The investigation process is biased toward certain departments
Correct answer: There is a systemic culture or control failure in those units requiring targeted intervention
Concentrated misconduct in specific business units signals systemic cultural or control issues that require targeted root-cause intervention rather than company-wide responses.
Question 7: What is the SCCE's primary standard for determining whether a compliance officer has sufficient independence?
- The CCO must hold a law degree
- The CCO must have direct reporting access to the board or audit committee (Correct answer)
- The CCO must be paid at least as much as the CFO
- The CCO must be employed for a minimum of three years
Correct answer: The CCO must have direct reporting access to the board or audit committee
The SCCE and leading governance bodies hold that genuine CCO independence requires direct reporting access to the board or audit committee, free from management interference.
CCEP Ethics Program Management 3
An ethics officer is designing a new hotline system.
Which feature is MOST critical to encouraging use?