Do Ethics & Code of Conduct Training Requirements Apply to All Employers – Both Public and Private?
Yes. The Federal Sentencing Guidelines apply to “all organizations, whether publicly or privately held, and of whatever nature, such as corporations, partnerships, labor unions, pension funds, trusts, nonprofit entities, and government units.”1 While the Sarbanes-Oxley Act applies to publicly traded companies, the rules and guidelines that it established are being widely adopted by privately held companies for two reasons: (1) Sarbanes-Oxley standards make for good business practice, adding value beyond simple “check the box” compliance. Many of the Sarbanes-Oxley requirements, like training, can help to substantially mitigate risk and liability for privately held organizations; and (2) Sarbanes-Oxley type legislation is expected in the near future for privately held organizations. Leading employers are recognizing the opportunity to stay ahead of the compliance curve.
