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Murphy and Moschella to OECD: Use existing compliance and ethics program models to promote public integrity

We recently filed comments with the Organization for Economic Cooperation and Development’s (OECD) Council on Public Integrity, making suggestions on the Council’s draft Recommendation on Public Integrity.

The OECD is a forum where the governments of 34 democracies with market economies work to promote economic growth, prosperity, and sustainable development.

The OECD Recommendation deals with promoting integrity in government, with an emphasis on the use of management techniques.

As background, we’re both actively involved with the Rutgers Center for Government Compliance and Ethics. (Joe is the chair and Emil is the executive director.) We are not writing this on behalf of Rutgers; we are writing as individuals.

Based on our decades of practical compliance and ethics experience, we suggested to the OECD that:

1. The Council on Public Integrity should use the concept of a compliance and ethics (“C&E”) program, as widely applied globally, as a starting point and model. C&E programs are already widespread — why reinvent the concepts?

2. The Council should consider using the OECD Working Group on Bribery’s Good Practice Guidance modified to address public integrity and public sector entities. These are good standards for compliance programs — why not use them?

3. The Recommendation should include a examples to illustrate how the suggestions in the Recommendation would work on a best practice basis.

4. The Council should include public international organizations, such as the OECD, in the scope of the Recommendation. We think it is good for those making recommendations to follow their own advice. 

5. The Recommendation should call on the public sector to promote C&E in the private sector to protect public integrity. If we want honest government it helps to promote integrity in the private sector, and C&E programs there help protect everyone.

6. The Council should advise states not to take actions that undercut C&E programs anywhere, whether in the private sector or the public sector. There have been some terribly ill-advised actions by governments that hurt C&E programs. Why have one part of government undermining something that another part is promoting?

7. The Council should form an ongoing working group to promote and implement the Recommendation. The Recommendation is good, and should have some ongoing life.

8. The Rutgers Center for Government Compliance and Ethics offers an important resource for development of public integrity programs. It’s a one-of-a-kind source for guidance on how government agencies can implement their own, internal C&E programs.  

*     *     *

We posted the actual filing here.

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Joe Murphy is the Advisory Board Chair of the Rutgers Center for Government Compliance and Ethics. He’s a Certified Compliance and Ethics Professional and author of 501 Ideas for Your Compliance and Ethics Program: Lessons from 30 Years of Practice (SCCE; 2008). He was co-founder and vice-chairman of the board of Integrity Interactive Corporation (now part of SAI Global). He serves on the board of the Society of Corporate Compliance and Ethics (SCCE). He can be contacted here.

Emil Moschella is the Executive Director of the Rutgers Center for Government Compliance and Ethics. He was with the FBI as an agent-attorney for over 28 years and served as Chief of the Legal Advice and Training Section of the FBI. Between 1997 and 2003 he was the Director of Corporate Compliance for Horizon Blue Cross Blue Shield of New Jersey. He recently completed assisting the FBI in the implementation of its corporate styled compliance program — a first in the federal government. He can be contacted here.

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