Here are a few highlights from KPMG’s 2009 Fraud Report:

• Two-thirds of executive reported that inadequate internal controls or compliance programs at their organizations enable fraud and misconduct to go unchecked.
• Seventy-one percent reported that they were most concerned about a potential loss of public trust resulting from fraud and misconduct in their organizations.
• The greatest room for improvement in their programs is employee communication and training.

Based on this report it seems the place to start is communication.  With so many tools available on the Internet, this should be easy to do.  But it all starts with the message, and the message comes from the Code of Conduct.  The more effective and inspiring the code, the better the message.  The better the message, the better the communication.  Better communication means that the program will ultimately be better.

Here’s another take: Bill Pawonka at Ethicspoint says: what’s important is that your organization have a strong ethical culture, a way to collect reports of misconduct, and a system to consistently investigate, document, resolve and ultimately analyze each report.