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  Ethics and Compliance Performance Audit from the City and County of Denver.
May 25, 2012 1:26 PMSCCE Social Media Manager
 

Ethics and Compliance Performance Audit from the City and County ...
From: SCCE Social Media Manager
To: Multi-Industry Ethics
Posted: May 25, 2012 1:26 PM
Subject: Ethics and Compliance Performance Audit from the City and County of Denver.
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This message has been cross posted to the following eGroups: Multi-Industry Auditing and Monitoring and Multi-Industry Ethics Forum .
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2010 Audits: http://www.denvergov.org/auditor/AuditServices/AuditArchives/Audits2010/tabid/440592/Default.aspx

November 18, 2012 E&C Performance Audit (attached in PDF)
http://www.denvergov.org/Portals/3/documents/Citywide%20Ethics%20Audit%20Report%2011-18-10.pdf

EXECUTIVE SUMMARY 

The City Has Developed an Ethics Program
The City of Denver has developed an ethics program, which allows  for  certain allegations of misconduct to be made and investigated, however the  City's  Board of Ethics (Board)  has limited jurisdiction to ultimately  review  matters involving alleged wrongdoing. The ethics program includes a Code of Ethics that prescribes acceptable ethical conduct in the areas of gifts, employment, conflicts of interest, and confidential information. The Code of  Ethics is overseen by the Board, which provides advisory opinions regarding ethical issues and adjudicates formal complaints. The Board comprises five volunteer members, who are selected by the Mayor, City Council, or, in the case of one member, by both the Mayor and Council. The Board has one full-time employee, the Staff Director, who assists the Board by addressing informal ethics inquiries, processing formal complaints, providing or assisting with ethics training, and other related tasks.

Complementing the role of the Code of Ethics and the Board is the City's whistleblower ordinance. The whistleblower ordinance encourages individuals who are aware of alleged  official misconduct to report this information to one of a variety of reporting entities, including the Mayor, City Council, City Auditor,  independent City Audit Committee, and the Board of Ethics. Importantly, the ordinance protects individuals who make good faith reports of official misconduct, so long as the  complainant  does not remain anonymous.

A Comprehensive Whistleblower Program Would Enhance the Impact of the Whistleblower Ordinance

While the whistleblower ordinance provides some encouragement for individuals to report official misconduct, a comprehensive whistleblower program should be developed to provide additional protection and encouragement for whistleblowers and to ensure that allegations are lodged with the proper City agency and formally investigated and closed.

One critical element that should be added is an anonymous-capable  whistleblower hotline (hotline). A hotline would give individuals a single point of contact, and can be readily publicized. Such a hotline would mark an improvement over the current system, which provides a bewildering array of reporting avenues and may prove confusing or 
even intimidating to potential whistleblowers, leading to a failure to report alleged misconduct. The multiplicity of reporting avenues may also result in an allegation being lodged with a City agency that lacks authority  and core competencies to investigate and resolve the matter.

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Thank you,

Eric Newman, Esq., CCEP
Social Media Manager
HCCA/SCCE
eric.newman@corporatecompliance.org
(952) 405-7938
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