Groups such as the Construction Industry Ethics and Compliance Initiative, Washington, D.C., and CMAA are leading the trend. Started by construction executives in 2008, the CIECI offers a blueprint for creating ethics programs, including writing a code of conduct, conducting awareness training and reporting problems. Many firms, including Dragados, have turned to CIECI to develop their programs.

Program Components

The key to an ethics program is upper management's will to create and maintain one. "Programs have to be CEO driven," says D'Angelo. "If you don't have buy-in at the top, you're just spinning your wheels."

Most ethics/compliance programs start with a code of conduct—a standard of behavior when dealing with people inside and outside the company. Granite Construction, for example, bases its ethics efforts on the Golden Rule: Do unto others as you would have them do unto you. Its conduct code has two sections: core values such as honesty, integrity, fairness and accountability, as well as compliance guidelines. Those include obeying the law, using generally accepted accounting principles in all finances, avoiding conflicts of interest and giving fair treatment to all sub and supplier bids.



Compliance initiatives usually include training to teach the code of conduct to employees, monitoring for violations (often including a 24-hour hotline), a disciplinary system for violations and a process for evaluating program effectiveness.



"People can learn to do the right thing," says Kathryn Marturano, government contracts compliance officer at PCL Construction Enterprises Inc., Denver. "I see people in the industry wanting to learn that."

"Granite made a commitment to the idea that a good offense is a great defense. It's a top-down commitment," says Michael Green, Granite Construction's compliance manager, who is also an attorney and accountant.PCL's program follows the basic template, and the firm requires employees, consultants and contract workers to know it and abide by it. Violations can result in disciplinary action, including termination of employment or services contracts.