| Course | BUS 560 Business Ethics |
|---|---|
| Module | Module 7 |
| Paper type | Compliance program evaluation |
| Length | About 1,033 words, 6 pages |
| Format | APA 7 student paper |
| School | Aspen University |
| Program | MBA |
| Updated | October 2026 |
Free sample paper for BUS 560 Module 7
A Code of Conduct in a Binder: Evaluating and Rebuilding a Paving Contractor's Ethics and Compliance Program
Student Name
MBA Program, Aspen University
BUS 560: Business Ethics
Instructor Name
Month Day, Year
A Code of Conduct in a Binder: Evaluating and Rebuilding a Paving Contractor's Ethics and Compliance Program
Ozark Asphalt and Paving, a composite company in Springfield, Missouri, paves roads and parking lots and produces asphalt at three plants. About 70% of its $140 million in annual revenue comes from public contracts awarded by competitive bidding by the state transportation department, counties and cities. The company has a code of conduct, adopted ten years ago, which sits in a binder in each office, and a telephone hotline that has received two calls in five years. After a competitor in a neighboring state was indicted for bid-rigging, Ozark's owners asked whether their own program would stand up to scrutiny. This paper evaluates it and recommends how to rebuild it. It is a learning example, and the company's counsel will advise on specific legal obligations.
The Company's Real Risks
A compliance program should begin with the risks a company actually faces. Ozark's are specific to public construction. The most serious is bid-rigging: agreements with competitors about who will win which contracts, or complementary bids designed to lose, which violate antitrust law and can lead to criminal prosecution and debarment from public work. The second is kickbacks or gifts to public officials, such as inspectors who approve work or accept materials. The third is falsified materials testing, for example reporting asphalt density results that were not achieved. The fourth is safety reporting on job sites with heavy equipment and traffic.
The Standards
Section 8B2.1 of the federal sentencing manual sets out what an effective program must contain (U.S. Sentencing Commission, 2024). In summary, an organization must establish standards and procedures to prevent and detect misconduct; ensure that its governing authority is knowledgeable and that specific high-level people have responsibility; avoid giving authority to people who have engaged in misconduct; communicate standards through training; monitor, audit and provide reporting channels without fear of retaliation; promote and enforce the program consistently through incentives and discipline; and respond to misconduct and prevent recurrence. The guidelines also call for periodic risk assessment.
Federal prosecutors judge a program on three fronts: the soundness of its design, whether it has the people, money and authority it needs, and whether it changes what happens in the company (U.S. Department of Justice, Criminal Division, 2024). Its guidance lists detailed questions under each, such as whether the program is tailored to the company's risks and whether employees use the reporting channels.
Scoring the Current Program
Four of seven elements are missing and none is adequate. The estimator bonus, which rewards winning bids without any compliance condition, works against the program.
| Element | Current state | Score |
|---|---|---|
| Standards tailored to risks | Generic code with one paragraph on antitrust | Partial |
| Leadership oversight | No named compliance officer; owners not briefed | Missing |
| Care in delegating authority | No checks before promoting estimators who prepare bids | Missing |
| Training | One video at hiring; nothing on bidding or public officials | Partial |
| Monitoring, auditing and reporting | No audit of bids; hotline answered by the receptionist | Partial |
| Incentives and discipline | Estimators' bonuses based only on contracts won | Missing |
| Response and prevention | No process for investigating reports | Missing |
What Research Says Works
Kaptein (2015), surveying thousands of employees across many companies, found that ethics programs with more components were associated with less unethical behavior observed by employees, and that some components, such as codes, training and accountability policies, mattered more than others. He also found that the sequence in which components are introduced matters: programs that build in a logical order, starting with clear standards and leadership commitment, appeared more effective than those that add pieces at random.
Why Public Contracting Raises the Stakes
Public contracts carry obligations beyond private ones. Contractors certify that their bids were prepared independently, that they have not offered anything of value to officials and that materials meet specifications. False certifications can lead to fraud claims as well as antitrust charges, and a conviction can bar a company from public work for years, which for Ozark would mean losing most of its revenue. Small favors that might seem harmless in private business, such as buying lunch for an inspector or sharing bid plans with a friendly competitor, can be serious violations in public contracting.
The Estimator's Position
Estimators prepare the bids that win or lose most of Ozark's work, and they meet competitors' estimators regularly at industry events and pre-bid meetings. Without clear guidance, a casual conversation about who plans to bid on which county contract can drift into coordination. Training must give estimators specific scripts for ending such conversations and a duty to report them to the compliance officer.
The Plan
Phase one, in the first three months, establishes the foundation. The owners will appoint a compliance officer, the chief financial officer for now, with a direct line to the owners and an outside counsel advisor. The code will be rewritten around the four real risks, with plain examples such as what to do if a competitor suggests coordinating bids. Estimators' bonuses will be conditioned on completing training and certifying each bid's independence.
Phase two, months four through nine, builds the operating parts. All estimators, project managers and plant managers will receive in-person training on antitrust rules and dealing with public officials. The hotline will move to an outside service with multilingual access and anonymous reporting. Materials testing will be audited by sampling independent tests.
Phase three, months ten through eighteen, adds review. Outside counsel will audit a sample of bids for signs of coordination, the compliance officer will report to the owners quarterly, and the company will survey employees on whether they would report concerns.
Cost
The plan will cost about $180,000 in the first year, mostly training, outside reporting services and counsel, and about $90,000 a year after that, small compared with the risk of debarment from public work.
Conclusion
Ozark's program existed on paper but would not satisfy the standards in the sentencing guidelines or the Justice Department's test of whether a program works. Rebuilding it around the company's real risks, in a sensible order and with incentives aligned to compliance, turns a binder into a program that can prevent and detect the misconduct most likely to harm the company.
References
Kaptein, M. (2015). The effectiveness of ethics programs: The role of scope, composition, and sequence. Journal of Business Ethics, 132(2), 415-431. https://doi.org/10.1007/s10551-014-2296-3
U.S. Department of Justice, Criminal Division. (2024). Evaluation of corporate compliance programs (Updated September 2024). https://www.justice.gov/criminal/criminal-fraud/page/file/937501/dl
U.S. Sentencing Commission. (2024). Guidelines manual ยง8B2.1. https://www.ussc.gov/guidelines/2024-guidelines-manual
Reading the BUS 560 Module 7 assignment instructions
Aspen's catalog for BUS 560 asks students to take business ethics seriously as part of how organizations operate, so in this module students judge, and if needed rebuild, a working ethics and compliance program. Use the directions for Module 7 in your classroom; this example evaluates and rebuilds one company's program. Identify the company's specific legal and ethical risks before evaluating its program. Use recognized standards, such as the federal sentencing guidelines and Justice Department guidance, cited precisely. Score the current program against those standards. Use research on which components actually reduce misconduct. Recommend changes in a realistic sequence with owners and resources. Explain how the company will test whether the program works, and note that legal advice is needed for specific obligations.
Inside the BUS 560 Module 7 example
The paper opens with Ozark Asphalt and Paving, its $140 million of revenue and its reliance on public contracts. A risk section identifies bid-rigging with competitors, kickbacks to public inspectors, falsified materials testing and safety reporting. The U.S. Sentencing Commission's guidelines manual lists seven elements, from standards and leadership oversight to response to misconduct, and is cited by section. The Justice Department's Evaluation of Corporate Compliance Programs supplies questions about design, resources and effectiveness. A seven-row table scores each element as missing, partial or adequate, finding the code of conduct generic and the hotline unused. Kaptein's Journal of Business Ethics study found that programs with more components, introduced in a sensible order, were associated with less observed unethical behavior. A three-phase plan follows with owners and costs.
Where the marks sit in the BUS 560 Module 7 rubric
Compliance program papers are evaluated on accurate use of authoritative standards, a risk-based analysis, honest scoring of gaps and a practical plan. This example identifies the company's specific risks first, so the program is evaluated against what could actually go wrong in public contracting. It cites the sentencing guidelines by section and quotes the structure of the Justice Department's evaluation questions, rather than paraphrasing general advice. Kaptein's Journal of Business Ethics study adds evidence about which components reduce misconduct. The gap table gives each element a score and a reason, and the plan sequences changes with owners and budgets. Testing whether the program works, through surveys and audits, shows awareness that regulators judge programs by their effect, not their existence.
Common BUS 560 Module 7 mistakes, and how to avoid them
Compliance program papers often list program elements without connecting them to the company's real risks. Start with the risks and evaluate each element against them. Another weakness is relying on general descriptions of what a program should include; cite the sentencing guidelines and Justice Department guidance precisely. Score gaps honestly, including elements that exist on paper but not in practice, such as an unused hotline. Use research on effectiveness so recommendations are not just a checklist. Sequence changes realistically; a small company cannot build everything at once. Assign owners and resources. Finally, explain how the company will know whether the program works, since an untested program is easy to overrate.
Write yours, or have the desk draft it
This paper is an original model document written by our desk, not a submitted student paper and not an official Aspen University document. Read it for the moves, then write your own to the instructions in your classroom. If you want one built to your exact prompt and rubric, the first custom sample is free and arrives in 24 to 48 hours.
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BUS 560 Module 7 questions, answered
What does BUS 560 Module 7 usually ask for?
Aspen's BUS 560 covers ethics and compliance programs in this module, so evaluating or designing a program for a company against recognized standards is typical. Follow your classroom prompt.
What are the elements of an effective compliance program?
The federal sentencing guidelines list seven, including standards and procedures, leadership oversight, training, monitoring and reporting, consistent enforcement and response to misconduct.
How does the Justice Department evaluate compliance programs?
Its guidance asks whether a program is well designed, whether it is adequately resourced and empowered, and whether it works in practice.
Where can I find a free BUS 560 Module 7 sample paper?
The complete evaluation appears above: a paving contractor's compliance program scored against the sentencing guidelines and Justice Department guidance, with research and a staged plan.
Do ethics programs reduce misconduct?
Kaptein found that programs with more components, introduced in a sensible sequence, were associated with less unethical behavior observed by employees.