“The ethics and compliance community suffers, in my view, from the absence of a standard, adopted framework for what an integrated, effective compliance program looks like.” These are the words of Jack Holleran, a principle at Ernst & Young, from Met. Corp. Counsel, Vol. 17, May 2009 at 8. Ernst & Young has built such a framework, which consists of more than 20 components. They have also built a maturity model, or “yardstick,” that their consultants use to assess the robustness of each program component on a 5-point scale, from basic to optimized.”
In my consulting projects, if I assess a law department, I apply a less formalized framework and maturity model. Each consultant to legal departments probably has what they would term a comparable diagnostic model, but no one has published such a framework. The legal department industry would benefit from a shared, comprehensive framework.