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November, 2002, Northeast Edition—Recent corporate scandals increased focus on compliance in the corporate sphere. The Sarbanes-Oxley Act of 2002, enacted in response to those scandals, has intensified that focus.

Editor: Would each of you describe your company and its products?

Jordan: Integrity Interactive Corporation (www.integrity-interactive.com) provides Web-based corporate ethics and compliance training and awareness. The Integrity Interactive team includes some of the leading authorities in the corporate compliance and ethics field—Win Swenson and Joe Murphy, for example along with a seasoned group of e-learning experts. Integrity's courses, which are designed by leading attorneys and other subject matter experts, are story-based for superior learning and retention. We've developed a process for ensuring that employees actually complete the right courses based on their compliance risk exposure.

Our clients—primarily Fortune 1000 companies in a wide cross section of industries—tell us that the combination of our expertise, high-impact courses, and superior client service has helped to make their compliance and ethics programs very effective.

Editor: Has interest in compliance-related products and services increased among law departments?

Jordan: Interest grew steadily during the 1990s after enactment of the Organizational Sentencing Guidelines. The Caremark decision by the Delaware Chancery Court in 1996 laid ultimate responsibility for compliance at the feet of the Board of Directors. More recent developments—Enron/Andersen and other corporate scandals, the new NYSE and NASDAQ listing requirements and Sarbanes-Oxley—have caused interest in this area from in-house counsel, senior management and the Board to skyrocket.

In-house counsel are increasingly sophisticated about this area. They ask hard questions about effective corporate ethics training programs. Will employees really take these courses? Will the company have a credible record that it has exercised ethics and compliance "due diligence"?

Editor: Which of your products have compliance-related uses?

Jordan: Integrity Interactive's sole business is to provide effective ethics and compliance programs. With our clients' help, we believe we're succeeding better than most folks imagined was possible.

We deliver Web-based ethics and compliance training to corporate employees. We cover the "risk landscape" with over 140 compliance and ethics topics. Clients are increasingly turning to us for help regarding their compliance programs beyond training. I expect we'll see more of this as the convergence of corporate governance and compliance accelerates.

Editor: In what area of law can you support a company's compliance efforts?

Jordan: The substantive areas of law in which we have developed compliance materials range from antitrust to government contracting to money laundering to sexual harassment to Internet privacy to the Foreign Corrupt Practices Act. We have over 140 compliance topics organized into about 25 discrete courses, such as Financial Integrity, Insider Trading, Earnings Management, Code of Conduct, Antitrust, Records Management and Conflicts of Interest.

Editor: Is your contact at a client company usually the corporate law department?

Jordan: Our client contact is often the general counsel. We also interact with other lawyers in the corporate law department. Interestingly, as corporate ethics and compliance has grown in importance—especially the corporate governance implications of this area—we've also found ourselves working with the corporate secretary, who has direct access to the Board of Directors.

Editor: Are in-house counsel important to a company's effective compliance program?

Jordan: In-house counsel are critical. A good compliance program educates employees as to "real life" legal and ethical risks—it does not try to turn them into lawyers. Companies have legal departments for that. A good program points employees to in-house counsel and other resources so employees can find answers to tough questions. In-house counsel are often in the best position to appreciate the risk of an ineffective compliance and ethics program, so they are often the most articulate advocates for enhancing compliance initiatives.

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