When should we act to prevent corrupt behavior in our company?
When an employee raises a concern? When an internal auditor includes an observation in a report? When outside advisors recommend that you strengthen your internal controls?
The makers of Jim Bean Bourbon chose to wait until they were fined $8.2 million by the U.S. Securities and Exchange Commission and $19.5 million by the Department of Justice.
Somewhere in your company, someone is asking you to spend money right now to improve your controls and your culture. And I bet they are not asking for millions.