1. Model Programs for Ethics and Compliance Catherine Sazdanoff Divisional Vice President, Ethics & Compliance Abbott March 30, 2006

2. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott What Makes a Model Program? Why have a program? Ethics, compliance, or both? Who runs it? Who owns it?

3. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Essential Program Tools Business-oriented staff Understand business environment, goals and challenges Proactive, creative, practical Want the business to succeed

4. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Rules That Make Sense Clear, simple language –No legalese, please User-friendly procedures –Intuitive, streamlined –Part of existing business processes Fast and handy support resources Make the right way the easiest way to get through the system

5. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Effective Training How does the business do it? Celebrate good news, learn from bad news Tailor to the audience Mix of vehicles Repeat, refresh Use regular business channels

6. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Monitoring and Auditing Self-checks for the business Real-time review Oversight Auditing

7. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Two-Way Communication Use business vehicle Provide multiple paths The personal touch

8. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Why Have a Program? CIAs and other catalysts Peer pressure BOD demands Company culture vs. problem avoidance

9. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Ethics, Compliance, or Both? Compliance alone Bright lines Technicalities Ethics alone Good intentions Ethics and compliance Why How

10. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Who Runs the Program? Too specialized vs. too diffuse Checks and balances Links to business Expertise Subject matter Process Communication Partnership

11. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Who Owns the Program? Too specialized vs. too diffuse Management: Setting expectations Leading by example Demonstrating commitment Employees: Personal integrity, pride Empowerment Responsibility

12. Model Programs for Ethics and Compliance March 30, 2006 © 2006 Abbott Signs of a Successful Program Past the basics People Time Money Goals Day-to-day