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The legal department, ethics hotlines and compliance officers (Raytheon)

Many businesses have an ethics officer whom employees can call anonymously to report a possible infraction. If employees do not want to call someone from their own company sometimes they can call a law firm that handles such reports. Often ethical complaints are reviewed by a committee on ethics and even by the Board. “Practices vary widely about how ethics violations are reported and responded to. Almost always, however, the general counsel is in the chain of analysis and response,” according to Jay B. Stephen, general counsel of Raytheon, in “The Defense Industry, Raytheon and Building a Compliance Culture,” Met. Corp. Counsel, Aug. 2005.

According to Raytheon’s Stephen, “We have an ethics officer who is sort of a progenitor of all the ethics, values, and cultural pieces but is also responsible for most investigations triggered by the ethics hotline inquiries. We also have a chief compliance officer who looks at the more straightforward legal compliance issues. They both report directly to me.”

A narrow interpretation of “legal” would bypass the general counsel when it comes to responsibility for ethics, compliance, and the farther reaches of risk management (See my posts of Aug. 27, 2005 on the general counsel as “reputational risk protector”; Sept. 4, 2005 #4; and Jan. 13, 2006 and McDonald’s scope.). Raytheon has taken one of the broadest interpretations of legal’s role.

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