The released articulation of compliance as a program came, perhaps surprisingly, from Federal Sentencing Guidelines, stepping back against a wave of corporate scandals involving bribery of foreign officials and other corporate wrongdoing. In 1991, the US Sentencing Commission submitted to Congress a guideline "To prevent and deter organizational wrongdoing." The guidelines set out the elements of an organization's compliance and ethics program, that would be needed to qualify for a reduced sentence if that organization were convicted of federal crimes. The elements are in your readings and you can read them in full there. But to cover them at a higher level here, let's go through the seven elements. One, standards and procedures to prevent unlawful conduct. What this is really saying is that a compliance program needs to establish what the rules of conduct are, whether in policies, a code of conduct, guidelines or other materials that we'll cover shortly. Two, there must be an individual with overall responsibility. In order to be effective, in other words, there needs to be accountability. The sentencing guidelines establish that there must be somebody with this role. Three, no delegation to known bad employees. What this is really suggesting is that an organization has an obligation to see who may or may not be violating the rules, and for those who are, there needs to be action against those employees, and usually, they need to be removed from the workplace. Four, effective training and awareness. Having policies on the shelf, as we'll talk about later, certainly doesn't go very far. Individuals and organizations must know what the rules are in order to adhere to them. Five, monitoring and auditing as well as a reporting line. There's quite a bit here. Again, we'll discuss in greater detail. But a compliance program must have a component that looks for inappropriate behavior. For violative behavior, they can use monitoring tools or auditing tools, and they must establish a reporting line for individuals to contact when they believe that there's something wrong that needs investigation. Six, consistent enforcement of standards through discipline. Finding violations is not enough, there must be action taken to addressing individuals who were involved in that wrongdoing. Lastly, responding to incidents through modification of the program. All organizations need to learn from their mistakes. I can't think of a single organization out there that hasn't had some sort of problem with compliance. But as the sentencing guidelines indicate, the organization needs to investigate what that problem is and make changes to try to reduce the chances of that problem occurring.