ERA Data Sheet 092205.

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The Ethics Risk Assessment

How do you know if your companys compliance and ethics
program are meeting the higher standards demanded by
regulators and the Federal Sentencing Guidelines?

Working Values and the Metrus Group have developed The Ethics Risk Assessment (ERA), a web-
based survey tool to assess employee attitudes and awareness of critical integrity and antifraud
risks as part of a complete ethics program evaluation.
ERA measures employee perceptions and attitudes on 36 key questions that provide clear
guidance on how well the company is doing in meeting its compliance goals and where it needs to
focus its training and communication efforts.
Key Benefits:
Maximize limited training and communication dollars and resources by focusing attention
on the areas that are generating the greater risk.
Provides a baseline measurement for leadership to gauge progress in meeting ethics goals.
A critical antifraud diagnostic to measure an organizations progress in creating an
environment where employees feel secure enough to report potentially fraudulent
activities.
Meet the Federal Sentencing Guidelines requirement for periodic measurement of the
effectiveness of an organizations ethics and compliance program.
Survey results will be used as part of annual program review to determine risk areas
requiring additional focus for communication and learning intervention.

Key Features:
Ease of useonly requires 10-15 minutes of respondents time.
Auto-generated report outlines impact of results and suggested remedial course of
action if required.
1 hour of consulting with a senior ethics professional to review the results and help
direct next steps.
Flexible design: two demographic options (with up to 10 selections per option)
permit the organization to generate up to 100 individual reports, such as sales
personnel in Region A, or Director level personnel in Region C.
Demographic Reports will show how each response compares with the overall
population in order to focus on areas that need specific attention and intervention.
ERA is the product combining the skills of two industry leaders, Working Values and The Metrus
Group.
Working Values has been a leading developer of values-based ethics and compliance solutions
for over 12 years. ERA is a core element in Working Values Integrity Alignment Process by
providing key baseline information about ethical behavior. Since 1988, Metrus Group has
provided high performance business tools, including balanced scorecards, employee surveys,
strategy mapping, supplier, customer, and internal alignment surveys, business acumen training,
and performance management.
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Background

The Ethics Risk Assessment provides a critical component in an organizations arsenal to reduce
the risk of fraud and criminal conduct and maintain high ethical standards. This Assessment is
used in conjunction with an organizations Code of Ethics and its internal controls management.
The Code of Ethics should reflect the organizations efforts to manage its legal risks as
indicated by the standards and policies outlined in the code document.
The organizations internal control reflects its efforts to manage risks related to insufficient
controls and processes.
This Assessment supports the organizations efforts to manage its Ethics Risks by providing the
Board of Directors, the Audit Committee and Ethics and Compliance managers with data on the
success of the organizations efforts to maintain an effective tone at the top and the ethical
environment in the organization.
Best practices in maintaining high standards dictated by the Federal Sentencing Guidelines as well
as the audit governing bodies emphasize the need to be alert to employees perceptions in the
implementation and enforcement of code standards and internal controls.
The AICPA recently noted that perceptions of managements commitment to uphold ethical
standards influence the degree to which employees and other parties follow the code and/or
report violations of the code. The extent to which management is perceived to be committed to
conduct sanctioned by the code will influence the organizations ability to deter, prevent, or detect
management override of internal controls and violations of the code. Equally important, an
evaluation by the audit committee of how effectively management communicates information
about the code and motivates employees to comply with the code also provides key information
about the culture. Employee awareness and training about the code may signal information about
managements commitment to the code and indicate the likelihood that employees will report
management code violations. Conversely, a lack of awareness by employees may signal
managements lack of commitment to ethical conduct.
Risks to Integrity
Legal Risks: Which laws and
regulations govern behavior?
Control Risks: Do internal
control processes address
Legal Risks?
Ethics Risks:
Do employees know what
they should do?
Culture Risks:
Will they do it?
Rules &Policies
Controls & Processes
Behaviors
Beliefs & Values

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How to Use the Survey

The results of the Ethics Risk Assessment should be used to create a benchmark for the
organizations program and serve as a basis for critical comparisons
of data.
In developing an action plan, an organization should look for
variances in relative scores among the six categories as well as
among the various demographic segments chosen to be surveyed.
The six categories known as the B CLEAR categories are: Beliefs,
Communication, Leadership, Equity, Awareness and Rules and
Regulations.
The survey results will help the organization deploy more focused
ethics and leadership training to the areas that need it most.
The organization should revisit the survey periodically to determine
if sufficient progress is being made in closing gaps the organization
identified in particular categories and among
selected demographic segments.


The Survey
Each of the six B CLEAR categories contains 6 multiple-choice questions. The client has the option
to include up to two demographics, (such as regions, business units, job function) with up to ten
choices within each demographic, thus providing a high degree of specificity for generating
reports.

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Administrators use a simple web interface to choose selected reports based on the chosen
demographics.
Results of each demographic can be compared against the whole population as well as other
demographics to determine trends and areas requiring special focus.


The survey purchase price includes an hour of consultation with a business ethics advisor who will
review the results and provide suggestions for next steps. The organization may look to develop
an action plan to address areas of concern, either organization-wide or within specific
demographics.
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The B CLEAR Categories

Each category reflects a key issue area that demands its own action plan to address weaknesses
and deficiencies. The 6 categories combine to create a complete picture of the ethical culture of
the organization.
Beliefs
Embedded cultural standards and norms of behavior
Six questions addressing the participants attitudes regarding the companys values and how they
relate to day to day work.
Employees who feel that their values are consistent and compatible with the companys are more
likely to take an active role in ensuring that they, and the people around them, act with integrity.
Nobody works in isolation from the people and the culture around them. Even employees with
strong personal values are less inclined to take action to do the right thing if that is not part of
the culture of the company.

Communication
Unrestricted and fear free, downward, upward, and lateral communications
Six questions addressing the participants perceptions of how well managers create an
environment that encourages open discussion of issues as well as how well they respond to issues
when they arise.

Most integrity troubles can be linked to two types of causes: Employees dont report unethical
conduct that they see, or they dont feel comfortable bringing bad news about mistakes or missed
objectives to their boss. In either instance, critical information is not communicated that perhaps
could allow management to resolve the issue before it becomes a problem.

Leadership
Belief that leaders can always be trusted to do the right thing
Six questions addressing the participants perceptions of how well managers set the right tone at
the top and act consistent with the companys values and policies.

It is not enough that a companys leadership is comprised of people with high degrees of personal
integrity. Leaders must actively demonstrate that integrity matters through their words and
actions. Employees look to their leaders to see how they handle tough business decisions with
integrity. They also look to their leaders to see which values are truly important and which are
given only lip service. Employees recognize the importance of the ethics message is more
determined by how the leadership integrates integrity into day to day business activity than it is
by issuing broad statements without active follow through.

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Equity
Perceptions of j ustice, fairness, and consistency
Six questions addressing the participants perceptions of how well the company treats all of its
stakeholders, both internal and external.
Every day your employees form impressions about how fairly they are treated. Was the process
used to evaluate my performance just? Does Jenna have the same opportunities as John? Are
there one set of rules for the executives, and another for the rank-and-file? Beyond the
importance of addressing the basic standards of fair-play, these issues are important to the
bottom-line of your business.
Awareness
Education that goes beyond merely informing people of the rules
Six questions addressing the participants perceptions of how well the participants understand
what is expected of them and how ethical behavior relates to their job and the companys
business goals.
In years past, simply recording employee attendance at mandatory ethics training could provide
employers with an affirmative defense. Based on recent proclamations by the SEC, U.S.
Sentencing Commission, and the Department of Justice, however, training has become a
necessary but insufficient aspect of your ethics and integrity strategy. The new standard has
become a true inculcation of the rules and regulations into the core of the company.
Reducing the risks of fraud and criminal activity requires coordinated compliance and ethics
training: Compliance training to inform employees on expected standards of behavior and ethics
training on how to create a positive environment as a preventative measure and how to address
ethical issues when they arise.
Rules and Regulations
Governance, formal systems and processes that support ethical conduct
Six questions addressing the participants attitudes towards the rules and regulations and whether
they are effective in guiding behavior.
Management override of internal controls is a leading source of fraud in organizations. This
dimension is not intended to assess the adequacy of the rules and regulations your organization
has put in place regarding breaches of ethical conduct; rather, it is intended to evaluate how
effectively the processes and systems that support day-to-day application of the rules and policies
are being implemented and communicated. Examples of such systems include;
Developing well-understood (and trusted) channels for reporting violations and
clear routes of appeal,
Continuing education programs to evaluate understanding and anonymous ways for
ethical violations to be reported should an employee feel uncomfortable using more
formal channels.
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Pricing
Pricing for the B CLEAR Ethics Risk Assessment is based on the number of the participants and
the number of reports. Organizations may select to poll the entire organization or a
representative sample of
Base Price includes one global report and 1 hour of consultation:
1 500 Survey participants: $1,200
501 2,500 Survey participants $1,700
2,501 - 5,000 Survey participants $3,500
5,001 - 20,000 Survey participants $5,000

Over 20,000 Survey participants Please call for quotation

The company may choose up to 10 selections for each of the two demographic segments, for a
total of 100 possible reports. The overall organizational report is included in the cost of the
survey, the cost for additional reports is
1-10 reports: $100 each
11-50 reports: $75 each
51-100 reports: $50 each

How to Order
The Ethics Risk Assessment survey is available for order from the web. For more information,
please visit us at www.metrusgroup.com/ethics/clients.php
or call Working Values at (800) 208-3535.