When I talked to Compliance and Ethics Officer Association Executive Director Keith Darcy the other day about the rising popularity of risk and ethics officers, he was emphatic about one thing: Companies with successful ethics programs have corporate cultures tied to a brand promise. Ethics programs that do not grow out of strong corporate cultures soon become nothing more than "check the box" exercises that won't accomplish much.

Darcy explains:

The brand promise at FedEx, for example, is "We'll deliver the package by 10 a.m. tomorrow." ...Watch the Tom Hanks movie "Castaway" again. It's a two-hour FedEx commercial... The guy's flying over the Pacific, the plane goes down...he lives on an island for five years. Eventually someone finds him, and at the end of the movie,...he delivers the package. But the person to whom he was delivering wasn't home, so he leaves a note with the package: "Thank you. This package saved my life." Metaphorically, work gave him meaning. That's the alignment of a strong culture to a brand promise.

And that's what every company should strive for, in Darcy's view. If employees know why they go to work every day and why they make the contributions they do, it works.

"Nobody wants to build [an ethics program] that is like having a full-time cop," he says. "The preferable alternative is to build a transparent, open organization." And companies do that by making sure their employees know what happens with calls to the anonymous fraud hotline, for instance. They'll publish the facts (with no names, of course) and the results of the investigations.

"If GE says 12 SVPs were fired for malfeasance, the message that gets back to the employees is, 'We heard you, and we acted on it.' It's affirming to employees, and empowering to employees," Darcy says.