Ethics and Compliance Review Template – Free Word Download

Ethics and Compliance Review Template – Free Word Download

Introduction

In the contemporary business environment, “Can we do this?” is a question of technical feasibility. “May we do this?” is a question of law. But “Should we do this?” is a question of ethics. The Ethics and Compliance Review is the governance mechanism designed to answer that final, critical question.

Project management has traditionally focused on the “Iron Triangle” of Scope, Cost, and Time. However, a fourth dimension has emerged as equally critical: Reputation. A project that is delivered on time and under budget but utilizes forced labor in the supply chain, discriminates against a user group, or inadvertently facilitates bribery is a failed project. It creates liability, damages the brand, and erodes stakeholder trust.

This template is a comprehensive screening tool used during the Project Initiation and Planning phases. It ensures that the project aligns not only with external laws (Compliance) but also with internal values and broader societal norms (Ethics). It covers a wide spectrum of risks, including anti-bribery/corruption, human rights, environmental sustainability, and the ethical implications of emerging technologies like Artificial Intelligence.

This document is not a passive checklist; it is an active risk management tool. It requires the Project Manager to engage with Legal, Compliance, HR, and Sustainability teams. By completing this review, you build a “moral fence” around your project, ensuring that your deliverables are sustainable, legal, and just.

Section 1: Project Profile and Ethical Context

1.1 Project Metadata

Instructions:

Establish the baseline for the review. Link this review to the specific initiative.

  • Project Name: [Enter Name]
  • Project ID: [Enter Code]
  • Project Sponsor: [Executive responsible for the project]
  • Region(s) of Operation: [List all countries where the project will operate, sell, or source materials.]
  • Review Date: [Date]

Guidance:

The “Region of Operation” is the single biggest indicator of compliance risk. Operating in Scandinavia carries a different risk profile than operating in regions with high corruption indices or unstable governments. Be exhaustive in listing locations.

1.2 The “Headlines” Test

Instructions:

Before diving into the legal details, apply the “Front Page Test.”

  • Scenario: Imagine the details of this project (how we source materials, how we treat workers, how we use data) were leaked to a major investigative newspaper.
  • Reaction: Would the organization be embarrassed? Would executives have to resign?
  • Initial Assessment: [Pass / Fail / Needs Review]

Section 2: Regulatory and Legal Landscape (The “Must Do”)

Instructions:

This section covers the hard laws. Non-compliance here leads to fines and jail time. Consult your Legal Counsel to complete this accurately.

2.1 Applicable Regulations Inventory

Table 2.1: Legal Requirements Matrix

Regulation DomainApplicable Law/StandardProject RelevanceCompliance Owner
Data Privacye.g., GDPR (EU), CCPA (USA), LGPD (Brazil)Project collects customer emails.Privacy Officer
Financial/Accountinge.g., SOX (USA), IFRS StandardsProject alters revenue recognition logic.CFO / Finance
Health & Safetye.g., OSHA (USA), HSE (UK)Project involves construction work.Safety Manager
Trade & Exporte.g., ITAR, EAR, Sanctions ListsProject involves shipping software code to Asia.Trade Compliance
Industry Specifice.g., FDA (Pharma), FAA (Aviation)Product is a medical device.Quality Assurance

Tips for Success:

Do not guess. “I think we are compliant” is not a defense in court. If you are unsure whether a law like the Foreign Corrupt Practices Act (FCPA) applies to your international vendor, mark it as “Review Required.”

Section 3: Ethical Framework and Corporate Values (The “Should Do”)

Instructions:

This section moves beyond the law to the company’s Code of Conduct.

3.1 Alignment with Core Values

Instructions:

List the organization’s stated values and test the project against them.

  • Value 1: [e.g., “Transparency”]
    • Project Alignment: [Does the project hide fees from customers? If so, it violates this value.]
  • Value 2: [e.g., “Diversity and Inclusion”]
    • Project Alignment: [Does the project team reflect the diversity of the user base? Is the product accessible to disabled users?]
  • Value 3: [e.g., “Sustainability”]
    • Project Alignment: [Does the project increase our carbon footprint?]

3.2 Conflict of Interest Check

Instructions:

Do any project team members or decision-makers have a personal interest in the outcome?

  • Vendor Relationships: Does any stakeholder have a family or financial tie to a selected vendor? [Yes/No]
  • Personal Gain: Will anyone on the team personally profit (outside of standard salary/bonus) from this project? [Yes/No]

Guidance:

Conflicts of interest are not necessarily illegal, but they are toxic to trust. They must be disclosed. If the Project Manager’s brother owns the construction company bidding on the work, the PM must recuse themselves from the selection process.

Section 4: Anti-Bribery and Corruption (ABC) Screening

Instructions:

Corruption risk is highest when dealing with third parties and government officials. This section screens for those risks.

4.1 Government Interactions

  • Question: Does the project require permits, licenses, or approvals from government officials?
  • Risk: [High/Medium/Low]
  • Control: [e.g., “All permit fees must be paid via official wire transfer to the agency bank account. No cash payments allowed.”]

4.2 Intermediaries and Agents

  • Question: Are we using “agents,” “consultants,” or “fixers” to facilitate business in a foreign country?
  • Risk: [High] (This is the most common channel for bribes).
  • Control: [e.g., “All agents must undergo Enhanced Due Diligence (EDD) background checks before contract signing.”]

4.3 Gifts and Hospitality

  • Question: Will the project involve entertaining clients or officials (dinners, travel, tickets)?
  • Limit: [e.g., “No gifts over $50 in value. No travel reimbursement for government officials.”]

Section 5: Labor and Human Rights

Instructions:

Modern slavery and unfair labor practices are significant risks, especially in supply chains (construction, manufacturing, agriculture).

5.1 Supply Chain Labor Standards

  • Suppliers: [Who are the primary suppliers?]
  • Location: [Are they in high-risk countries for child labor or forced labor?]
  • Verification: [Do we audit them? Do they hold certifications like SA8000?]

Table 5.1: Human Rights Risk Assessment

Risk AreaProject ExposureMitigation Strategy
Child LaborSourcing textiles from SE Asia.Require suppliers to provide age verification records.
Forced LaborConstruction crews in the Middle East.Ban the practice of withholding passports from migrant workers.
Working HoursSoftware team crunch time.Monitor overtime hours to prevent burnout and violation of labor laws.

5.2 Discrimination and Harassment

  • Policy: Confirm that the project has a clear mechanism for reporting harassment.
  • Culture: ensure the project environment (including vendor sites) is free from discrimination based on race, gender, religion, or orientation.

Section 6: Environmental Impact

Instructions:

Every project consumes resources. Evaluate the environmental cost.

6.1 Carbon Footprint

  • Travel: [Will the project require extensive air travel? Can it be done remotely?]
  • Energy: [Will the new data center increase energy consumption?]
  • Mitigation: [e.g., Purchase carbon offsets; use LEED-certified buildings.]

6.2 Waste and Lifecycle

  • Physical Waste: [What happens to the old hardware we are replacing?]
  • Circular Economy: [Can the materials be recycled? Is there a “take-back” program?]

Example:

“The project involves replacing 500 laptops. We will contract with an e-waste certified recycler to ensure they are not dumped in a landfill illegally.”

Section 7: Technology and Data Ethics (AI & Algorithms)

Instructions:

If your project involves Artificial Intelligence (AI), Machine Learning (ML), or extensive data mining, this section is mandatory. Technology can unintentionally discriminate.

7.1 Algorithmic Bias

  • Question: If an algorithm makes decisions (e.g., granting loans, screening resumes), what data was it trained on?
  • Risk: [e.g., “The training data is historical, which reflects past biases against minority groups. The AI might replicate this bias.”]
  • Mitigation: [e.g., “We will test the algorithm for ‘Disparate Impact’ before release.”]

7.2 Transparency and Explainability

  • Question: Can we explain why the AI made a decision?
  • Requirement: Users have a right to know why they were rejected. The “Black Box” problem must be addressed.

7.3 Surveillance and Autonomy

  • Question: Does the technology monitor employees or users excessively? (e.g., keystroke logging, eye tracking).
  • Ethical Check: Is this level of surveillance proportional to the business need? Or does it violate dignity?

Section 8: Risk Scoring and Action Plan

Instructions:

Summarize the findings. Assign a risk level to each category.

Table 8.1: Ethics Compliance Scorecard

CategoryRisk Level (H/M/L)Critical FindingsRequired Action
Regulatory[Low]Standard compliance needed.None.
Anti-Bribery[High]Project uses agents in a high-risk zone.Mandatory Legal Review of all agent contracts.
Human Rights[Medium]Supplier audit is expired.Schedule audit before first PO is cut.
Environment[Low]Digital-only project.None.
Tech Ethics[High]AI model has potential bias.Conduct ‘Fairness Test’ on the algorithm.

8.2 The “Stop Work” Triggers

Instructions:

Define what findings would cause you to immediately pause the project.

  • Trigger 1: Evidence of bribery or kickbacks.
  • Trigger 2: Discovery of child labor in the supply chain.
  • Trigger 3: Legal Counsel advises that the project violates sanctions.

Section 9: Whistleblowing and Grievance Mechanisms

Instructions:

Ethics is an ongoing process. You must provide a safety valve for people to report issues during the project lifecycle.

  • Mechanism: [e.g., Anonymous Hotline, Web Portal, Ombudsperson.]
  • Communication: [How will the project team and vendors be informed of this hotline?]
  • Non-Retaliation: [Confirm policy: No one will be fired or punished for reporting a concern in good faith.]

Section 10: Sign-Off and Certification

Instructions:

This is a serious attestation. The signatories are certifying that they have reviewed the risks and are comfortable proceeding.

10.1 Project Leader Certification

“I certify that I have reviewed the ethical and compliance implications of this project. To the best of my knowledge, the project plan adheres to all applicable laws and the company Code of Conduct.”

  • Project Manager: ___________________________ Date: __________

10.2 Compliance Officer Review

“I have reviewed the identified risks and the proposed mitigation plans. I approve the project to proceed subject to the stated controls.”

  • Compliance Officer: ________________________ Date: __________

Conclusion – Ethics and Compliance Review Template – Free Word Download

The Ethics and Compliance Review is the project’s moral compass. It protects the organization from the catastrophic costs of scandal and litigation. More importantly, it ensures that the project contributes positively to the world.

A project that passes this review is robust. It has nothing to hide. It treats people fairly, respects the law, and protects the planet. By embedding these considerations into the DNA of the project at the start, you avoid the nightmare scenario of having to recall a product, halt a construction site, or face a government investigation halfway through execution.

Keep this document alive. If the project scope changes for example, if you enter a new country or switch to a new supplier you must revisit this review. Ethics is not a one-time checkbox; it is a continuous commitment to doing the right thing, even when no one is watching.

Meta Description:

A comprehensive Ethics and Compliance Review template to assess project risks related to legal regulations, anti-bribery, human rights, environmental impact, and AI ethics.

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