Preface xiii
Acknowledgments xvii
About the Author xix
CHAPTER 1 Why Ethics and Compliance Will Always Matter 1
CHAPTER 2 Tone at the Top and Throughout 25
CHAPTER 3 The Growth and Evolution of Compliance 45
CHAPTER 4 Caremark and Sarbanes-Oxley: Enhancing Compliance 71
CHAPTER 5 CA's Compliance Rebirth: Don't Lie, Don't Cheat, Don't Steal 87
CHAPTER 6 The International Landscape of Compliance 107
CHAPTER 7 Compliance Programs and Anti-Money Laundering Efforts 131
By Marc B. Sherman, Laura Connor, and David Meilstrup
About the Chapter Authors 148
CHAPTER 8 Interview with an Ethics and Compliance Thought Leader 149
CHAPTER 9 Building a World-Class Compliance Program: The Seven Steps in Practice (Part I) 163
CHAPTER 10 Building a World-Class Compliance Program: The Seven Steps in Practice (Part II) 191
CHAPTER 11 Recognizing Compliance Excellence: Premier, Inc. and Winning the Baldrige Award 219
CHAPTER 12 Designing Robust Fraud Prevention Policies: The Airservices Australia Fraud Control Plan 233
CHAPTER 13 The Skunk in the Room 257
Appendix A: Summary of the 2004 Federal Sentencing Guidelines Amendments and Recommended Action Steps 269
Appendix B: Sample Compliance Program Charter 277
Appendix C: Resources for Compliance Professionals 283
Index 291
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