Step-by-Step Guide: EHM2 Task 3: Code Of Ethics And Legal Responsibility Analysis

EHM2 Task 3: Code Of Ethics And Legal Responsibility Analysis

Introduction

As a leader in your organization, it is vital that you are familiar with the laws that regulate your industry. Sparked by the dramatic corporate and accounting scandals of Enron, Arthur Andersen, Adelphia, and WorldCom, the Sarbanes-Oxley Act was implemented in 2002 in an effort to restore confidence in the stock markets. Sarbanes-Oxley represents the most important securities legislation since the original federal securities laws of the 1930s as it increased governmental regulation and oversight of publicly traded companies and established protections for whistleblowers. The False Claims Act and the Dodd-Frank Wall Street Reform and Consumer Protection Act provide a financial incentive for those who blow the whistle to report fraudulent activity within their organization.

In this task, you will select and analyze an established company’s code of ethics, analyze how an employee would raise an ethical concern within an organization, and consider current laws with respect to whistleblowers.

Scenario

You are an experienced ethics officer who has recently been hired by an established company. You have been tasked with analyzing the company’s current code of ethics and identifying areas in need of improvement.

Requirements

Your submission must represent your original work and understanding of the course material. Most performance assessment submissions are automatically scanned through the WGU similarity checker. Students are strongly encouraged to wait for the similarity report to generate after uploading their work and then review it to ensure Academic Authenticity guidelines are met before submitting the file for evaluation. See Understanding Similarity Reports for more information.

Grammarly Note:

Professional Communication will be automatically assessed through Grammarly for Education in most performance assessments before a student submits work for evaluation. Students are strongly encouraged to review the Grammarly for Education feedback prior to submitting work for evaluation, as the overall submission will not pass without this aspect passing. See Use Grammarly for Education Effectively for more information.

Microsoft Files Note:

Write your paper in Microsoft Word (.doc or .docx) unless another Microsoft product, or pdf, is specified in the task directions. Tasks may notbe submitted as cloud links, such as links to Google Docs, Google Slides, OneDrive, etc. All supporting documentation, such as screenshots and proof of experience, should be collected in a pdf file and submitted separately from the main file. For more information, please see Computer System and Technology Requirements.

You must use the rubric to direct the creation of your submission because it provides detailed criteria that will be used to evaluate your work. Each requirement below may be evaluated by more than one rubric aspect. The rubric aspect titles may contain hyperlinks to relevant portions of the course.

Prepare a report (suggested length of 6–8 pages) in which you do the following:

A. Choose a company’s code of ethics from the Web Links section below and analyze that company’s code of ethics by doing the following:

Note: Links to the code of ethics for the companies can be found in the Web Links section. The code of ethics is only used for section A. You must choose a code of ethics from one of the following companies:

• BP
• Comcast
• Deloitte
• Tenet
• Mayo Clinic
• Oracle
• PepsiCo
• Target
• Walmart
• Wells Fargo

1. Analyze how well the chosen company’s code of ethics covers the topic of corporate social responsibility (CSR).
2. Analyze how well the chosen company’s code of ethics covers the topic of compliance with legal mandates.

a. Describe the ramifications for an organization when it is noncompliant with legal

b. Describe two policies the chosen company has in their code of ethics to ensure employees behave legally and/or

3. Analyze how well the chosen company’s code of ethics facilitates the development of an ethical

4. Identify three resources available to employees to use when raising an ethical concern and discuss which resource you would most likely use to report an ethical

B. Discuss three factors an employee might consider before deciding to report unethical conduct observed at

1. Describe three internal steps (i.e., inside the company) an employee could take if they decide to report or blow the whistle on misconduct or unethical behavior in the workplace.

2. Describe two possible external actions (i.e., outside the company) an employee can take to report or blow the whistle on misconduct or unethical behavior in the workplace.

C. Analyze one advantage and one disadvantage of paying Base your analysis on one of the following laws:

• • False Claims Act

  • Dodd-Frank Wall Street and Consumer Protection Act

D. Analyze the changes that organizations have made based on the S. Sentencing Guidelines.

1. Discuss three culpability factors that are used to determine fines under the U.S. Sentencing Guidelines.

E. Acknowledge sources, using in-text citations and references, for content that is quoted, paraphrased, or summarized

F. Demonstrate professional communication in the content and presentation of your submission

Step-by-Step Guide: EHM2 Task 3: Code of Ethics and Legal Responsibility Analysis

QUICK REFERENCE: Assignment at a Glance

STEP 1 — Choose Your Company (Section A)

Before writing a single word, choose your company from this approved list: BP, Comcast, Deloitte, Tenet, Mayo Clinic, Oracle, PepsiCo, Target, Walmart, Wells Fargo.

Recommended pick for ease of writing: Mayo Clinic or Target — both have detailed, publicly available codes of ethics that explicitly address CSR, compliance, culture, and employee reporting mechanisms, making it much easier to satisfy every rubric criterion.

💡 Strategy: Choose a company whose code of ethics you can actually access and read before writing. Skim the document first and confirm it discusses: (1) environmental/social responsibility, (2) laws and compliance, (3) ethics reporting mechanisms, and (4) culture/values language.

⚠ Do NOT try to write Section A from memory. You must reference the actual code of ethics document. WGU evaluators will know if you invented or misrepresented the content.

STEP 2 — Read the Code of Ethics Critically

Once you select your company, read the full code of ethics with the following four questions in mind, taking notes under each:

1. Where does this code address the company’s responsibility to society, environment, and communities? (CSR — A1)
2. Where does this code discuss obeying laws, regulations, and avoiding violations? (Legal compliance — A2)
3. What two specific, named policies address legal/ethical employee behavior? (A2b)
4. How does the code create a culture of ethics — training, leadership modeling, accountability mechanisms? (A3)
5. What reporting tools does the code mention for raising concerns? (A4)

💡 Depth Tip: The rubric rewards ‘well-supported’ analysis. Every claim about the code must be tied to specific language or section names in the document. Vague praise like ‘the code is very thorough’ will earn Approaching Competence, not Competent.

STEP 3 — Write Section A: Code of Ethics Analysis

A1 — Corporate Social Responsibility (CSR)

What to write: Explain how the code addresses CSR — the company’s obligations beyond profit, including environmental stewardship, community investment, diversity/inclusion, ethical supply chains, and stakeholder welfare.

Structure your A1 paragraph like this:

• Open by defining CSR briefly in your own words (1–2 sentences).
• Identify specific sections or language from the code that address CSR themes.
• Analyze how well those sections cover the topic — are they vague commitments or measurable goals?
• Note any gaps — what is missing that a strong CSR framework would include?

💡 Example opener: The [Company] Code of Ethics addresses corporate social responsibility through its commitments to environmental sustainability, community engagement, and ethical sourcing. The section titled ‘[exact section name]’ outlines…

A2 — Legal Mandate Compliance

What to write: Analyze how the code handles legal compliance. Look for references to specific laws (e.g., Sarbanes-Oxley, FCPA, anti-bribery), regulatory bodies, audit processes, and compliance training.

Your analysis should address: Does the code merely say ‘obey all laws’ or does it name specific areas of legal risk and explain how the company manages them?

A2a — Ramifications of Noncompliance

What to write: Describe what happens to organizations that fail to comply with legal mandates. This section is not about the specific company — it is about general legal consequences. Include:

• Civil penalties and financial fines (e.g., SEC enforcement, DOJ settlements)
• Criminal liability for executives and the organization
• Reputational damage and loss of public trust
• Debarment from government contracts
• Operational disruption — increased oversight, consent decrees, mandatory audits

💡 Cite Here: Reference a real law. For example: Under the Sarbanes-Oxley Act (2002), organizations that commit securities fraud may face criminal penalties of up to $5 million and 20 years imprisonment for executives, and civil fines that can reach hundreds of millions for the corporation.

A2b — Two Specific Policies

What to write: Choose two named or clearly defined policies from the company’s actual code of ethics. These must be specific — not just ‘we follow the law’ but actual policies with names, defined requirements, or measurable standards.

Examples of what qualifies as a ‘policy’ for this rubric:

• Anti-bribery and corruption policy
• Conflict of interest disclosure policy
• Data privacy and information security policy
• Non-retaliation policy for reporting misconduct
• Political activity and contributions policy

⚠ Do not describe general values like ‘integrity’ or ‘respect’ as policies. They must be specific procedural policies from the code document.

A3 — Development of an Ethical Culture

What to write: Analyze whether the code of ethics goes beyond rules to actually build a culture of ethics. A strong ethical culture involves: leadership accountability, ongoing training, open communication channels, reward systems for ethical behavior, and embedded values.

Ask yourself: If a new employee read only this code, would they understand how to make ethical decisions in gray areas? Would they feel safe reporting concerns?

Structure: Identify 3–4 cultural mechanisms in the code (e.g., annual ethics training, leadership modeling language, tone-at-the-top messaging, ethics hotline integration) and evaluate how effectively each builds ethical culture.

A4 — Three Resources for Raising Ethical Concerns

What to write: Identify three resources available to employees within the company for raising ethical concerns. Then explain which one you would personally use and why.

Common resources found in codes of ethics:

• Ethics hotline / whistleblower hotline (anonymous reporting)
• Direct supervisor or manager reporting chain
• Human Resources (HR) department
• Ethics and Compliance Officer or department
• Internal Audit function
• Board of Directors / Audit Committee (for serious matters)

💡 Personal Choice: When explaining which you would use, give specific reasons tied to the resource’s features — e.g., ‘I would use the anonymous ethics hotline because it protects reporter identity, reducing fear of retaliation, while ensuring the concern is documented and routed to the appropriate compliance officer.’

STEP 4 — Write Section B: Employee Decision to Report

B — Three Factors Before Reporting

What to write: Discuss three factors that might influence whether an employee decides to report unethical conduct. These are real psychological and practical considerations — not moral lectures.

Strong factors to discuss:

• Fear of retaliation — concerns about job loss, demotion, or social ostracism
• Uncertainty about whether conduct is actually unethical vs. a misunderstanding
• Trust in the reporting system — does the employee believe action will be taken?
• Severity of the misconduct — minor policy violation vs. fraud affecting the public
• Loyalty to colleagues or supervisors involved in the misconduct
• Personal risk tolerance and financial vulnerability (e.g., sole breadwinner)

💡 Depth: Each factor should be 2–4 sentences. Define the factor, explain why it matters to the reporting decision, and connect it to real organizational dynamics. Do not just list — analyze.

B1 — Three Internal Whistleblowing Steps

What to write: Describe three specific steps an employee can take within the organization to report misconduct. These must be inside the company.

1. Report to immediate supervisor — the first step in most organizations; document the concern in writing and retain a copy.
2. Escalate to HR or the Ethics & Compliance Officer — if the supervisor is unresponsive or involved, bypass them and go directly to a neutral internal authority.
3. Use the anonymous ethics hotline — allows reporting without revealing identity, creating a documented record for internal investigation.

B2 — Two External Whistleblowing Actions

What to write: Describe two actions outside the organization. These involve regulatory agencies, government bodies, or legal counsel.

• File a complaint with the SEC (Securities and Exchange Commission) — applicable to publicly traded companies; protected under Dodd-Frank.
• Submit a qui tam lawsuit under the False Claims Act — applicable when fraud involves federal government funds; the whistleblower (relator) may receive 15–30% of recovered funds.
• Report to OSHA — for workplace safety violations or retaliation claims.
• Contact the Department of Justice — for criminal fraud, corruption, or antitrust violations.
• Consult an employment attorney specializing in whistleblower law — to assess legal protections and strategy before going public.

⚠ Choose two and explain them in detail — what agency is involved, what the process looks like, and what protections apply.

STEP 5 — Write Section C: Advantages and Disadvantages of Paying Whistleblowers

What to write: Analyze one advantage AND one disadvantage of paying whistleblowers. You MUST tie your analysis to either the False Claims Act (FCA) or the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Recommended Law: Dodd-Frank Act (2010)

Advantage to write about: Financial incentives encourage reporting that might otherwise never occur. Under Dodd-Frank, the SEC’s whistleblower program pays 10–30% of sanctions collected in cases over $1 million. This incentivizes insiders — who have unique knowledge of fraud — to come forward despite personal risk.

Disadvantage to write about: Financial incentives can generate frivolous or opportunistic claims — individuals may report minor or ambiguous conduct hoping for a payout, overwhelming compliance and investigative resources. It can also undermine internal reporting systems, as employees may bypass company channels to go directly to regulators for financial gain.

💡 False Claims Act Alternative: Under the FCA, relators (whistleblowers) who file qui tam suits can receive 15–30% of government recoveries. Advantage: massive recoveries in healthcare and defense fraud. Disadvantage: litigation-driven process that can be lengthy, expensive, and weaponized competitively.

STEP 6 — Write Section D: U.S. Sentencing Guidelines

D — Organizational Changes Based on U.S. Sentencing Guidelines

What to write: The U.S. Sentencing Guidelines for Organizations (USSG Chapter 8, 1991/2004 revision) incentivized companies to create formal compliance and ethics programs. Analyze the specific changes organizations have made as a result.

Key organizational changes to discuss:

• Establishment of formal Ethics & Compliance programs with dedicated officers (Chief Compliance Officer roles)
• Creation of anonymous ethics hotlines (now standard across Fortune 500 companies)
• Mandatory ethics training programs for all employees at hire and annually
• Board-level oversight of compliance — Audit Committees given direct authority
• Documented internal reporting structures and investigation procedures
• Self-monitoring, auditing, and risk assessment processes

💡 Key Argument: Before the Guidelines, organizations had little structural incentive to proactively prevent misconduct. The Guidelines created a direct financial reward (reduced fines/culpability scores) for having robust ethics programs, fundamentally reshaping corporate governance.

D1 — Three Culpability Factors

What to write: The USSG uses a culpability score to determine the size of fines. The base score of 5 is adjusted up or down based on specific factors. Discuss three:

Factor 1 — Involvement of High-Level Personnel

If senior management was involved in or tolerated the misconduct, the culpability score INCREASES significantly (by +2 to +5 depending on organization size). The rationale: leadership sets culture; executive wrongdoing is more blameworthy than isolated employee actions.

Factor 2 — Prior History of Similar Misconduct

Organizations that have previously been sanctioned for similar violations face a higher culpability score (+1 to +2). This factor penalizes repeat offenders and rewards organizations that take corrective action after first violations.

Factor 3 — Existence of an Effective Compliance and Ethics Program

A well-implemented ethics program — meeting all seven USSG criteria — can reduce the culpability score by up to 3 points, resulting in substantially lower fines. The seven elements include: standards, oversight, training, monitoring, reporting mechanisms, discipline, and response to detected problems.

💡 Bonus Factor: Self-reporting to authorities before discovery also reduces culpability (-1). This creates a strategic incentive for voluntary disclosure of wrongdoing, which benefits both the organization and government enforcement.

STEP 7 — Citations and References (Section E)

WGU requires APA 7th edition. Here is what you must do:

• Every fact, law reference, or claim borrowed from an external source needs an in-text citation: (Author, Year) or (Author, Year, p. X) for direct quotes.
• Sources you will likely cite: the company’s code of ethics, the Sarbanes-Oxley Act, Dodd-Frank Act, False Claims Act, U.S. Sentencing Guidelines, and at least 2–3 peer-reviewed journal articles or authoritative sources.
• Your reference list must include: Author(s). (Year). Title. Source/Publisher. URL (for online sources).

Sample APA references:

U.S. Sentencing Commission. (2023). Guidelines manual. https://www.ussc.gov/guidelines/guidelines-manual

[Company Name]. (Year). Code of ethics and business conduct. [Company Name]. https://[URL]

⚠ Do not cite Wikipedia. Use .gov, .org, company official websites, peer-reviewed journals (accessible via WGU library), or recognized legal sources like Cornell Law’s LII.

STEP 8 — Format and Polish (Section F)

WGU uses Grammarly for Education to assess professional communication. Your paper MUST pass Grammarly before submission. Follow these steps:

1. Write in Microsoft Word (.docx format only — no Google Docs, no PDF for main submission).
2. Target 6–8 pages (roughly 1,800–2,400 words of body text). Do not pad; do not go drastically under.
3. Use APA 7 formatting: 12pt Times New Roman or Arial, 1-inch margins, double spacing, APA title page, running head optional for student papers.
4. Label each section clearly: ‘A1: Corporate Social Responsibility’, ‘B: Factors for Reporting’, etc.
5. Run Grammarly BEFORE submitting. Fix all Correctness errors. Then run WGU’s similarity checker and review the report.

FINAL SUBMISSION CHECKLIST

Before uploading, confirm every item below is in your paper: