[PDF] Give Me Something I Can Teach Building a New and Improved

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Give Me Something I Can Teach

Building a New and Improved Global Code of Business Ethics: The Accenture Approach In a world of increasing globalization and transparency, ethical action plays a major role in how corporations do business today. Corporations are setting higher standards for themselves and their employees which in turn put more emphasis on their codes of conduct. Accenture, with 140,000 employees in 48 countries, adopted its first company Cod e of Busi ness Ethics in Novemb er,

2001. The

Code was the foundation of the company's new Ethics and Compliance program and synthesized key policies and core values. In early 2005, the Ethics and Compliance Program Manager, Jay Mumford, began examining the Code, which had barely changed in nearly four years. He concluded that although the Code content was accurate and met the applicable legal requirements, Accenture people in the field needed a more

practical document. Tinkering at the edges of the document, he thought, would not be enough. It needed

a fundamental overhaul of both structure and presentation. In January 2006, Mumford got the approval

from Doug Scrivner, the Compliance Officer, General Counsel and Secretary, and sponsor of the Code of

Business Ethics.

Scrivner authorized the team to move ahead with revising the Code, and set the timeline to September 1,

2006, the first day of Accenture's fiscal year. The team had just eight months.

The First "Aha" Moment

In February, Mumford was in Paris for a European Ethics Officer Conference on Business Conduct. Accenture Chairman & CEO William D. Green was also in Paris attending a meeting with the company's

Legal group. After Green's presentation, Mumford introduced himself and briefly described his plans for

the Code project. Green had known this project was underway and after listening to the update, looked at

Mumford and said, "Give me something I can teach." These simple yet powerful words resonated with Mumford and set the project's tone and approach - create a teachable document.

Building the Team

Back home, Mumford realized he needed a bigger team and began bringing more people into the

process. He reached out to the policy sponsors and their coordinators to review the Code and assess the

required policy content for the revision, as well as several team attorneys, including Karianne Kas,

European Counsel for Labor and Employment, and Phil Storm, Americas Counsel for Labor and

Employment, to review the legal content.

Fran Janik, the Legal group's Marketing & Communications lead, was brought in from the beginning.

Janik played a role in bringing the team together, securing a creative services agency to design our Code

to reflect the Accenture brand and to develop a communications plan. Her responsibility was essential in

communicating with the right teams within the organization and interfacing with the global communication

channels. This also included tying in the main messages and themes of the organization. Next, Mumford and Janik added a professional writer, Simon Maple, to the team. Maple's job was to

manage the document's content, balance competing inputs and craft the text to meet the interests of each

stakeholder - Legal, Marketing, the outside world and internal "readers," who ranged from a senior executive in the United States to an analyst in India or the Philippines.

Mumford and Janik then added a graphic designer, Jenny Rodriguez from Schawk, Inc. to create the new

look and feel of the Code in pdf and print formats. Rodriguez had a wide breath of design experience on

other Accenture projects and this knowledge and experience was critical in creating a design that

adhered to the company's brand standards. She helped the team work more efficiently, especially in the

review and approval process with the Core Values team from the Accenture Brand Management

Department.

Mumford added Teresa Latuszek to the team because with many different facets of the project, the scope

and complexity of this effort demanded a dedicated project coordinator. Teresa came from Aquent a Building a New and Improved Global Code of Business Ethics:

The Accenture Approach staffing firm. The team used Microsoft Project Manager as a key tool to guide all tasks and responsibilities

for each team member (See Exhibit 1).

The team also used a share point site - a centralized location on the web - to store and share documents

for all key members to access. This site was very useful in keeping track of the documents and in maintaining version control.

Harvesting a Global Perspective

Mumford also reached out to the local geography leads, the "Geographic Ethics Champions" to gain their

support. He asked them to organize and run local focus groups, which were held in France, India, Italy,

Japan, the Philippines, Singapore, the UK, and the US. These champions' assigned facilitators and

Mumford developed a facilitator's guide form to be used in the face-to-face meetings. The groups were

set up for one-hour sessions, with a facilitator to provide a write-up to the project coordinator for posting.

We also created an electronic version of the survey for groups who could not meet one-on-one; the electronic version was mainly used in India. The facilitators asked the following Focus Group questions: • Question: Have you ever read the Code of Business Ethics before this meeting? (We wanted to establish a tone of candor!) • Question: Is the meaning/content of the Code of Business Ethics clear? What would make it easier to understand and more useful?

• Question: What does the Code of Business Ethics mean to you? What does it represent for you?

• Question: Which sections are most useful? Which sections are most "tough"? Which sections are most surprising or unexpected? The questions were aimed at getting the real picture on what people thought about the previous Code

and what they wanted to see in the new and revised Code. The feedback from these local countries was

instrumental in helping us create a document useful to all employees. In February, the team members started looking over the Code. The look and feel of the document was legal in tone and made up of seven sections. It was very text-heavy with no graphics or diagrams (See

Exhibit 2).

Exhibit 1

Building a New and Improved Global Code of Business Ethics:

The Accenture Approach

The team was also reviewing many other company codes and thought Accenture's Code needed a

different emphasis from its current Code. The challenge was to create a resource that Accenture people,

including the stakeholders, could actively use. The objective was for the Code to be a "living document" in

the company and stay current with internal and external developments. But we still needed a fundamental

structure that would endure and unify the Code's many critical pieces; we were missing the essential

element to tie it all together.

The Second "Aha" Moment

In March, Mumford attended a Conference Board Global Council on Business Conduct meeting in Washington, DC. Between sessions, he spoke with Mark Damschroder from Caterpillar, about the Code

project. It turned out that Mark had recently worked on revising his own company's code of ethics. Mark

explained how Caterpillar had structured their document on the company's core values, using action

statements to illuminate the concepts. The structure of the document telescoped from the pre-existing

and long-standing Caterpillar values to the actions to the supporting text. They had seen good success

with this structural approach, because the concept was straightforward and drove home a direct connection between the company's values and the company's code. This code/values/action statement

concept was the missing link we were looking for to bring the whole project together. Chad Fentress, the

Associate General Counsel & Director of Compliance & Regulatory Affairs, and Scrivner could quickly see

how the concept tied the pieces together in a way that would make sense to the employees, and backed

the idea.

In addition, our focus group feedback reinforced that the Code was difficult and cumbersome to read.

Some felt it was too general and others didn't know how the Code applied to them. They wanted specific

examples and not just a recitation of policies.

With the groundwork started, we organized ourselves around the following process steps: design scripting

content development, review and communications and the roll-out.

Building a Living Document

We wanted to create a world-class document that included a letter from the CEO, a letter from the Compliance Officer, our core value framework with action statements (See Exhibit 3), a visual executive summary (See Exhibit 4), extensive Q&As (See Exhibit 5), scenarios, the Accenture Ethical Decision-making

Model, the "Five Cs" - a tool designed to help our employees make the best decision by drawing on the

strengths of colleagues and the company - as well as hyper-links to policies and an index of key terms.

With this framework in mind, Maple and Mumford worked on the first draft of the Code. In creating the

scenarios and Q&A sections, Maple looked at several other company codes Caterpillar, Borealis, IBM and West to name a few. He chose and wrote 30 scenarios and Q&As and collaborated closely with the core team and worked them into the new structure of the Code.

Exhibit 2

Building a New and Improved Global Code of Business Ethics:

The Accenture Approach We invited the Core Values team to be part of our Code revision project team and set up weekly status

calls to keep everyone in synch and ensure the Core Values and their definitions were communicated and

used consistently.

The Core Values team had just gone through a reinvigoration of the company's core values within the last

year. Accenture has six core values: Stewardship, Best People, Client Value Creation, One Global Network, Respect for the Individual and Integrity. They had chosen specific images to represent each core value's meaning. This effort integrated well with the revision of the Code. We chose to represent each core value in the Code with these same images, along with a summary statement, action statements and an extended definition . Building a New and Improved Global Code of Business Ethics:

The Accenture Approach

Core Value

Imagery

Summary

Statement

Core Value

in action

Extended Definition Core value thumbnail

On each page

Each action statement

represented in Code for each core value Each action statement represented in Code throughout each core value

Exhibit 3

Building a New and Improved Global Code of Business Ethics:

The Accenture Approach

Exhibit 5

Exhibit 4

Extensive

Q&A's

Building a New and Improved Global Code of Business Ethics:

The Accenture Approach

Did anyone read it?

The two milestone dates the team worked towards were the Accenture July board meeting and a set release date in September to coincide with the new fiscal year. The July board meeting was the cornerstone date we targeted to have the document as close to complete as possible. We then assembled an internal review team and communicated with them early and often. The team

consisted of the Code project team and other employees throughout the organization from all levels. We

also enlisted a review panel of sixteen "real" people across the company. Also on the review team was

the Ethics and Compliance Subcommittee, a panel of 10 members of the Executive Leadership Team, who oversee the Ethics and Compliance Program. The policy sponsors were also asked to review.

Finally, we also invited senior executives who sponsor specific policies to review the concept and the

content to ensure appropriate coverage of key policies.

The team set the expectation to the review team that we would reach out to them during several phases

of the process. Our first draft and review focused on the planned structure of the document and the

practicality of the new layout and approach. The second draft focused on the clarity of structure and the

clarity of language in the document. The first two drafts sculpted the look and feel of the new Code and

the language in it. For draft three, we reached out to several other groups in the organization to get an in-

depth review of the Code as a whole. This review of a near-final draft was important to identify any gaps.

The reviewers consisted of the audit committee, board of directors, outside counsel (a noted expert in

compliance and ethics programs), internal expertise (a litigation attorney) and a proofreader.

From an efficiency and practicality standpoint, we aimed to have the right reviewers at the right time. For

each review, we gathered comments and placed them in one master document. We used the share point

site to host these responses for Maple to easily access. Maple had the challenging task of incorporating

and addressing everyone's comments into the document. It was important to the process to have one person manage the master document in order to keep track of all the changes and maintain version

control. Also it was critical to draw the line on responses coming in. This was challenging at times,

especially towards the end of the process when deadline dates were critical and many people wanted to

review and/or comment on the document one last time.

Once the reviews were final and the document stamped for final approval, Rodriguez had the last task of

adding the hyper-links to the policies, links to the navigation bars on each page and links to the pages in

the index (See Exhibit 6). Building a New and Improved Global Code of Business Ethics:

The Accenture Approach

Exhibit 6

Once the links were in the pdf, Rodriguez sent us the final designed Code of Business Ethics file.

Enlisting the help of several different countries, we commenced a final global testing procedure to ensure

all links were accurate and working properly. After eight months of collaborative work, the final Code was

declared ready for release.

Policy Links

Navigation Bar

Building a New and Improved Global Code of Business Ethics:

The Accenture Approach

Best Practices and Lessons Learned

In summary, best practices and lessons learned coincided. Our top lessons learned are:

1. Build your team with the right people and expertise.

2. Include people from all areas of your organization.

3. Win executive support: This played a major role in being able to meet our goal of significantly

revising our Code in only eight months.

4. Set the expectation and let all groups involved know what is going on throughout the process.

5. Take the time to think about each task to complete in your process and estimate appropriate time

for each task. Set realistic deadline dates for each task and keep them in tact.

Keep an eye out for a future publication where we'll focus on the communications and roll-out process for

the Accenture Code of Business Ethics

Greater Houston Business Ethics Roundtable

Engaging Your Workforce with an Interactive Online Code of Ethics

Jay Mumford, Vice President, Ethisphere Institute

July 2013

What we'll discuss today an exciting emerging area How can you maximise the effectiveness of your on- line code of ethics? How can the EC function best use emerging web tools on your intranet to achieve your goals with employees? What are the ways of keeping staff engaged with your code (that you worked so very hard to create)?

2Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Let's do a quick poll ...

1.Are you using the web to achieve your program goals?

2.Is your code "on-line"? (Does "on-line" only mean that

there's a PDF file of it embedded on the EC website?)

3.Are you using innovative ways of keeping staff coming

back to your site to get new information?

3Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

What is "Code 1.0, Code 2.0, and Code 3.0"

Code 1.0, Code 2,0, or Code 3. Which code do you have? Why should you care? What are the key factors for success in a Code 3.0 world?

Command and control mentality

Scarcity mentality

Sprinkled through our discussion, a case study: One Code of Conduct as it travelled through Code 1.0, 2.0, and 3.0.

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Let's look in more detail at Code 1.0 and Code 2.0 Code of conduct 1.0 - the legalistic, heavy lawyer-driven code of days past. Perfectly legally accurate, but not terribly useful for the average employee. Code of conduct 2.0 - Today's code at leaders such as certain tech, beauty products, and energy companies are "2.0" codes. They are impressive documents, and very much more useful than 1.0 models, tying the company's values together with behaviors that help employees understand the behaviors they need to embrace. But they can be still somewhat static, plus difficult and expensive to update - a bit like an encyclopedia, published, pretty, a bit forbidding. May be often kept on the shelf for "when we really need it." Forward thinking compliance professionals at these companies have augmented their codes with extensive education and awareness activities, as well as periodic certifications that require employees to acknowledge receipt and comprehension of the code.

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Let's look in more detail at "Code 3.0"

Code of conduct 3.0 - Far more dynamic, accessible, open. It contains an enduring core of the values and behaviors, but then a quite dynamic set of additional "rings" or layers of content that make the core accessible to employees and users. Elements of this dynamic content could be submitted by employees and then vetted by the Ethics and Compliance Office. One dynamic ring could be a collection of scenarios and then mapped back to the action statements, another content ring would be Questions and Answers that are linked back, also information on company policies, reporting lines ...

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Let's look in more detail at Code 3.0 (cont.) ... and the core plus the dynamic integrates with the corporate ethics and compliance training approach. Overlaying each ring, content is grouped for easy access by particular "slices" of employees, such as managers, senior leaders, employees in

Sweden, or by business unit.

Underneath it all must be a powerful search capability, to bring content from each ring and the core to the fingertips of the employee on demand. The promise of COC 3.0: Escape from being a static published PDF document on the e-shelf to a much more flexible platform, and incorporate web 2.0 technology to be an active part of the business ethics dialog in the company every day.

7Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

recap: What are some of the standard factors for analyzing any code of conduct? There are eight criteria that capture the key considerations:

1.Public availability

2.Tone from the top

3.Readability and tone

4.Non-retaliation and reporting

5.Values and commitments

6.Risk topic coverage

7.Comprehension aids

8.Presentation and style

We want to do well across all these criteria ... but realize too that the bar is being raised as workforces and expectations change!

8Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

The "Notable Nine" Success Factors for a

successful Code of Conduct "3.0" In addition to "regular" critical success factors for a code, your 3.0 Code must

1.It must be liberated from the PDF - this mentality must pervade

2.It must be searchable - or better still, content should be "findable"

3.It must contain practical information

4.It should be dynamic - the site must have something bringing folks

back for more

5.Have clear ownership for every piece of content - no orphan content!

6.It should be available in multiple languages- in real time...

7.It should be "on the pathway" between an employee and their job ...

where you can get away with it!

8.Be ready to iterate your way forward thru measurement and updates

9.It should have a pathway to becoming a multi-platform code - "your

code, your way"

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Notable Nine Success Factors

#1. Liberated from the PDF

1."The Code must be liberated from the PDF - this mentality must pervade"

Dusty old PDF files on the e-shelf are so2012! Hard to use, hard to open, annoying to scroll around in ... but with some benefits. Look for content elements, scraps everywhere ... and free them up. Liberate, reuse, repurpose! A ny Q&A's in the code should be available via multiple non-code channels Training scenarios should be harvested, repackaged Other content segments in training that introduction topics Quiz, game, or other tests that judge content understanding should be reused

Blog postings can be harvested

Speeches by leading executives

The Code itself should be freed from the confines of the PDF file ... with many implications: constancy; keeping printed versions up to date; just what is "the" code; what do our employees certify to, anyway?

10Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Notable Nine Success Factors

#2. Searchable

2."The Code must be searchable - or better still, content should be "findable"

Searching isn't finding ... that's a bit of a zen thing to say Being listed in search results anywhere after page 1 doesn't count ... top 3 items would be best Have your content unified "virtually" ... other sites that address compliance and ethics topics can still exist, but they should be brought into a unified approach. This can be tough to do when SME's are autonomous, and have content expertise (but not communication) How can you be sure that your content is findable? Be good friends with your IT team ... and you need them more than they need you!

Key word setup - SME's to the rescue

Tagged with behind-the-scenes data flags to support automatic mapping of content to search terms Is there a guaranteed-find capability in your search engine? If so, use it.

Check check check

Just because they can find the code PDF doesn't mean they can find what they are really looking for ...

11Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Notable Nine Success Factors

#3. Practical

3."The Code must contain practical information"

The Code isn't the spot for analysis of the Kantian imperative, the annals of Jeremy Bentham, or the Socratic method as applied to the virtuous life ... No waxing philosophical, sorry! (At least not in plain view.) Your focus should be upon making practical information available. Going further, build the system such that it can customize content for the individual viewer by country, major work team. Better still, "remember" the user and retain what they reviewed most recently.

What types of practical content do you need?

Scenarios scenarios scenarios scenarios scenarios! Frequently asked questions (best case, periodically refreshed) Links to policy/procedures, to games, to quizzes (can be built upon scenarios) Think about tapping into the great mass of enthusiasm and energy flowing just outside your office door ... right, your employees! How can you help them help you?

12Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Notable Nine Success Factors

#4. Be Dynamic

4."The Code portal should be dynamic - it must have something bringing

folks back for more" Static is boring ... "last updated Feb 29, 2008" is not going to impress! Your Code portal should continually contain new and engaging content, packaged in an engaging way, so viewers will have reason to return time and again.

Where does the content come from?

Content owning teams

Employees (thru a structured process)

Other company publishers.

External news feeds

And how do folks tell you what they are interested in, so that when new information is available on a topic of interest they can be told automatically by the system and invited to review and respond to the information?

13Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Notable Nine Success Factors

#5 .

Clear ownership (and it's not all on you)

5."Have clear ownership for every piece of content - no orphan content!"

Creating the code isn't "fire and forget" ... keep the SME's engaged EC teams should have a structured approach to identifying and maintaining contact with the true SME owners of Code content across the company. What are the duties of your content SME's? (consider a network of them, which you might call the SMENetwork or SMEnet) Their duties could include: Participate in quarterly meetings with EC team members Identify what ethics and compliance means in their specific domain Actively promote the Code on their own pages (if you can't enforce a standard layout). Check this by periodic review.

Use available resources

Provide content for assets that need to be developed Help your content owners to not be in the position of leaving the "baby on the orphanage steps" ... the baby being their content and the orphanage being the code!

14Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Notable Nine Success Factors

#6. Language support

6."Content should be available in multiple languages- in real time..."

Don't be an inadvertent language "imperialist" (or an advertent one, for that matter!) Translating a 25 to 45 page PDF into 5, 10, 20 languages is nice, but not really enough - imagine if you are a new employee in Asia with an introductory level of English ... In the typical "translated PDF file" approach, we imply that the following steps will happen:

1.Employee will decide that there is useful content in the code of conduct

2.Employee will go find the English code PDF and wait for it to download

3.Employee will actually open it, not having been pulled away by now

4.Employee will scroll to and fro or find what they need

... all the while, doing this in a 2nd, or 3 rd language, which depending on policy, they may not even be required to speak

5.Employee will then find something useful in English, but want to see it in native tongue.

6.Employee will then find the clickable link to their language PDF copy, and repeat steps 2,

3, 4...

At any point in these six steps we could lose that employee! So, how do you liberate your code content from the PDF? Make it available in language, on-line!

15Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Notable Nine Success Factors

#7. Measure and iterate7."Iterate your way forward thru measurementand updates based on findings"

Measurement approach

1.Begin with a weekly metrics activity report

2.Shift to bi-weekly when you can

3.Even monthly if that's realistic

Build a standardized and simple assessment process

1.Use ready-made tools to send a short weekly survey to nvisitors

2.Take the time to analyze the feedback

3.Make changes to website, as necessary

The natural pressure is to NOT measure; to NOT know; to build the site and leave it alone. Resist this pressure! Or as they don't say in the movie title: "Just because you build it, they won't necessarily come."

16Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Notable Nine Success Factors

#8. Be on the road to somewhere folks have to go

8."Be on the pathwaybetween an employee and their job ..."

Classic set up is work is over here, code is over there, EC training is o'er yonder, and Business Ethics Helpline is somewhere else again ...

Code 3.0 means bringing those things together

But also having multiple-platform support would be best ... can you support: A gifts and entertainment tool that employees must use to register gifts and entertainment should be (only?) accessible via the gifts and entertainment page Code of conduct computer-based training or in-person training should force employees to work their way through the site, gathering answers as they go and learning how to the use the materials

Other examples?

... be subtle enough that folks don't feel you are forcing them to take a detour and slowing them down.

Every SME's content page should refer back to their content in the Code portal; the pay and expense tool should contain clickable links to the Code portal; be imaginative in how many ways you can steer employees via the Code portal.

17Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Notable Nine Success Factors

#9. Aim towards a multi-platform code

9."Have a pathway to becoming a multi-platform code - "your code, your way"

PDF is the minimum (print may not be really needed, apart from a minimal copy count) Code 3.0 with a full supporting on-line portal is better still But also having multiple-platform support would be best ... can you support: A separate app on the desktop? At the least, a link in the standard desktop build iPhone and iPad versions of all/part of the code

Android versions of all/part of the code

Windows 7 versions of all/part of the code

... don't feel bad, I don't know of any who can ... yet! What we are really talking about is making key parts of your code, your reporting mechanism, or your compliance and ethics applications available for the traveling, busy, non-Wi-Fi mobile user. The "stranglehold" of the desktop has clearly cracked ... mobile computing is not looking back ... is your Code going to be ready for this huge opportunity to be where your employees need you - and it - to be?

18Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Web Layout Design

ExpertiseLanguage Translation

Capabilities - and ability

to see beyond the PDF file into the siteTechnology skills to build the site - and probably going "in-house" through your IT organization will not work

Scenario development

skills, Q and A development for the short-format environmentWeb Vendor Management Tech skills to integrate in with growing social media capabilities

Technical skills to create

a mobile-platform version (3.1)Ability to set up and run focus-group and interviewing skills for the online systemAbility to integrate the site "backwards" into your LMS and other platforms

Web Writing/Scripting Even more

communications and marketingWeb data analysis skills This is a major challenge and is not to be underestimated!

Got it! Now let's build the Code 3.0 ...

Creating Code 2.0 is tough enough! But Code 3.0 also demands

19Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.

Key Attributes of a Code 3.0

Web/cloud-based interactive code of conduct portal - a platform. Ties together your text/PDF code plus the whole range of content to help your employees understand, apply, and discuss your code. The Code can be laid out as a virtual book, if that helps employees feel comfortable with it. See the great Cisco example. Each compliance area "topic" has its own "page," so if 20 topics, then 20 main content pages. Employees find just what they need, nothing they don't. AndDedicated pages for helpline, for leadership messages, for index, etc. Branded for your organization, employees do not know/care where the content is actually hosted (such as in the cloud) Automatically receive new feeder content from multiple sources Using tagging, make new content automatically "findable" Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.20

Code 3.0: Content Types and Access Methods

assetAnti- corruptionGifts and entertainm entIPSales

ComplianceTopic X, Y,

Z Video

Policy links

Tools FAQ CBT

Training

Quizzes/

games

Blog/Discu-

ssion board

Scenarios

Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.21

The virtualCode 3.0 ... mock up of a sample topic

TOPIC X

Training

links

Video

links SME access S M E B L O G

Top Scenarios

(matched to demographics of visitor)

Top FAQs (matched to

demographics of visitor)

Top FAQs (matched to

demographics of visitor)

Policy

links Tool

Access

links

Key "core"

content on the topic, which does not change•Key Idea 1 •Key Idea 2 •Key Idea 3Scrolling quotes from leaders; internal "tweets", or other changing content Copyright (c) 2013 Ethisphere Institute. All Rights Reserved.22 23
Contact InformationCopyright © 2013 Ethisphere Institute . All Rights Reserved.Jay C. Mumford

Vice President, Ethisphere Institute, Inc.

jmumford@ethisphere.com+1 925 322-1529 http://ethisphere.com Copyright and Intellectual Property Notice: Ethisphere Institute owns and maintains the copyright and intellectual property in this presentation. Any unauthorized use of these materials is prohibited.

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