Ethics Program Management Flashcards

The False Claims Act's qui tam provision primarily incentivizes which behavior?

Answer: Whistleblowers reporting government contractor fraud by sharing in recovered funds

The FCA's qui tam provision allows private individuals to file lawsuits on behalf of the government and receive a portion of the recovered funds for exposing fraud against the government.

A compliance officer is presenting the annual ethics program report to the board. Which type of information is MOST valuable to board members fulfilling their oversight role?

Answer: Trend data on hotline reports, substantiation rates, and corrective actions taken

Board members need trend data on program outputs — hotline activity, substantiation rates, and corrective actions — to assess whether the compliance program is functioning effectively.

Which of the following BEST illustrates 'proportionate discipline' in an ethics program?

Answer: Applying consistent sanctions calibrated to severity, intent, and cooperation

Proportionate discipline means calibrating sanctions to the seriousness of the violation, the employee's intent, and their cooperation — ensuring fairness and deterrence.

A compliance officer is evaluating whether to use a 'speak-up' ambassador program. Which outcome BEST justifies this investment?

Answer: Increased early reporting of potential issues before they escalate

Ambassador programs are designed to create trusted peer contacts who encourage early reporting, which allows compliance issues to be resolved before they become serious violations.

Which of the following is a key distinguishing feature of an 'ethics-based' compliance program compared to a 'rules-based' compliance program?

Answer: It emphasizes values and judgment rather than checklists and prohibitions

Ethics-based programs cultivate values and principled judgment so employees can navigate novel situations, while rules-based programs rely on specific prohibitions that cannot anticipate every scenario.

Under the EU Whistleblower Protection Directive, what minimum internal reporting channel requirement must covered organizations establish?

Answer: Secure confidential channels with acknowledgment within 7 days and feedback within 3 months

The EU Whistleblower Protection Directive requires covered organizations to establish confidential internal channels, acknowledge reports within 7 days, and provide feedback to reporters within 3 months.

A compliance officer discovers that a business unit leader consistently pressures subordinates not to use the ethics hotline. What is the MOST appropriate response?

Answer: Escalate the behavior to senior leadership and the audit committee as a program integrity threat

A manager actively suppressing hotline use represents a serious threat to program integrity that requires immediate escalation to senior leadership and the audit committee, not just remedial training.