Why an External Assessment of Ethics and Compliance Programs is Beneficial
Not long ago, a client asked me a straightforward question: Why is an external assessment of an ethics and compliance program beneficial?
It is a fair question. Many companies invest heavily in their compliance infrastructure, train their employees, and measure culture internally. So why bring in an outside perspective?
The answer is that external assessments are not only a best practice but increasingly an expectation of regulators, investors, and boards. They provide the credibility and objectivity that internal reviews alone cannot deliver. More importantly, they turn compliance into a source of business strength.
A Defensible Program
The U.S. Department of Justice (DOJ) makes it clear that a defensible compliance program is one that is periodically evaluated for effectiveness. Both the DOJ’s Evaluation of Corporate Compliance Programs and the U.S. Federal Sentencing Guidelines emphasize the importance of regular, independent reviews. These reviews demonstrate that leadership is serious about accountability and continuous improvement, and they provide evidence that can mitigate penalties if issues ever arise.
Informed Decisions and Better Alignment
Executives and boards want data. They want to know whether their programs align with peer practices and regulatory expectations. External assessments answer these questions with rigor.
They benchmark programs against the world’s leading companies, highlight areas of risk, and prioritize improvements. This is not about checking a box but about making smarter decisions on where to allocate resources, how to structure governance, and how to address emerging risks like AI, supply chain transparency, or data privacy.
Culture Matters
As regulators like Kenneth Polite Jr. have emphasized, it is not enough to have a program on paper. The real test is whether employees believe leadership models integrity, whether they feel comfortable raising concerns, and whether the company responds appropriately when they do. External assessments that include culture measurement provide an unfiltered view of how employees perceive ethics and compliance. That perspective is often the most valuable data a leadership team can have.
A Business Advantage
The world’s most ethical companies consistently outperform their peers. Independent validation of a compliance program is not just about risk reduction; it is about creating trust with employees, investors, and customers. It signals to stakeholders that the company is not merely avoiding misconduct but actively building a culture of integrity. That trust translates into stronger employee engagement, better relationships with regulators, and long-term business resilience.
Closing Thoughts
When I was asked why an external assessment is beneficial, my first instinct was to point to regulatory expectations. But the more complete answer is that external assessments create clarity, credibility, and confidence. They allow compliance leaders to move faster, defend their programs more effectively, and demonstrate to all stakeholders that ethics and compliance are not just policies but principles that drive performance.
For companies serious about integrity, an external assessment is not an expense. It is an investment in trust, resilience, and sustainable success.
