Directors as Guardians of Compliance and Ethics Within the Corporate Citadel: What the Policy Community Should Know by Michael D. Greenberg

Author:Michael D. Greenberg [Greenberg, Michael D.]
Language: eng
Format: epub
ISBN: 978-0-8330-5082-3
Publisher: Center for Corporate Ethics and Governance a Rand Institute for Civil Justice Center
Published: 2010-09-15T00:00:00+00:00

1 As pointed out by two of the papers (Brown’s and Darcy’s; see Appendix C) for the symposium, the 2004 amendments to the FSG specifically address the responsibility of directors in “requiring that board be knowledgeable about the content and operation of the C&E program” and that directors “must reasonably oversee the implementation and effectiveness of the program.”

2 See Hansen’s paper in Appendix C.

3 In this regard, the proposed 2010 revisions to the FSG would create direct incentives for an unfiltered reporting channel between the board and the CECO. See U.S. Sentencing Commission, 2010, p. 18.

4 The newest revisions to the FSG are slated to become effective on November 1, 2010. For details, background, and commentary, see U.S. Sentencing Commission, 2010, p. 18.

5 On this point, see also Murphy, 2009.

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