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                            Small 
                              to Medium Enterprises
                            SME 
                              Conversion Table
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                      Leading 
                        enterprises, government agencies, and NGOs have found 
                        that an effective Corporate Responsibility Program addresses 
                        eight responsibility functions:  
                     
                    
                      -  
                        
High-level 
                          responsibility for program oversight (the "Responsible 
                          Officer") 
                       
                      -  
                        
Performing 
                          or coordinating the specific functions of the Corporate 
                          Responsibility Program (the "Corporate Responsibility 
                          Officer") 
                       
                      -  
                        
Advising 
                          the Responsible Officer and Corporate Responsibility 
                          Officer and representing the enterprise as whole (the 
                          "Corporate Responsibility Council") 
                       
                      -  
                        
Advising 
                          the Responsible Officer, Corporate Responsibility Officer, 
                          and employees and agents about specific professional 
                          ethics, compliance and social responsibility issues, 
                          such as biomedical, engineering, or community issues 
                          (the "Professional Ethics Council") 
                       
                      -  
                        
Linking 
                          various levels of the enterprise with a central ethics 
                          office ("Business Conduct Representatives") 
                       
                      -  
                        
Related 
                          executive and department functions, such as the Chief 
                          Financial Officer; Legal Counsel; Human Resources; Internal 
                          Audit; Environmental, Health and Safety; government 
                          procurement; and Investor Relations 
                       
                      -  
                        
The 
                          individual responsibility of every employee and other 
                          agent of the enterprise to abide by the standards and 
                          procedures and strive to meet reasonable stakeholder 
                          expectations 
                       
                      - 
                        
Other 
                          stakeholders, including owners/investors and suppliers/service 
                          providers.  
                       
                     
                     
                      Though 
                        discussed separately, the nature of the enterprise and 
                        its size, complexity, and resources may argue for combining 
                        any number of them. Informal channels and reporting relationships 
                        can also be integral parts of Corporate Responsibility Program 
                        design. 
                       
                      
                         
                          |  
                             Corporate Responsibility Infrastructure SME Conversion Chart 
                           | 
                         
                         
                          |  
                             Function 
                               
                           | 
                           
                             Typical 
                              SME Staffing 
                           | 
                         
                         
                          | High-level 
                            responsibility for program oversight (the "Responsible 
                            Officer") | 
                          Often 
                            an owner, but another highly respected employee, who 
                            has substantial authority in the enterprise, is preferable. | 
                         
                         
                          | Performing 
                            or coordinating the specific functions of the Corporate Responsibility Program (the "Corporate Responsibility Officer") 
                             | 
                          Typically, 
                            a respected staff member performs or coordinates the 
                            functions of the Corporate Responsibility Officer. An SME can 
                            form or join a business association to develop training 
                            materials and provide a forum for managers to discuss 
                            ethics, compliance, and social responsibility issues, 
                            problems, and solutions. The SME can employ an independent 
                            answering service to provide a mechanism for employees 
                            and agents to seek advice or report concerns anonymously. 
                            The SME can use an outside service to conduct a periodic 
                            evaluation of its Corporate Responsibility Program. | 
                         
                         
                          | Advising 
                            the Responsible Officer and Corporate Responsibility Officer 
                            that represents the enterprise as whole ("Corporate Responsibility Council") . | 
                          An 
                            SME can conduct regular meetings of all or representative 
                            employees, perhaps 30-60 minutes per meeting, once 
                            a month, to discuss enterprise core beliefs; standards, 
                            procedures, and expectations; and current ethics, 
                            compliance, and social responsibility issues. A medium 
                            enterprise, especially one with multiple locations, 
                            can appoint members to such a council, but meet regularly 
                            by telephone. An SME can form or join a business association 
                            to provide a forum to discuss current ethics, compliance, 
                            and social responsibility issues, problems, and solutions. 
                            A college, university, or business development council 
                            might host a forum for SMEs. A large enterprise can, 
                            and often should, host a forum for its suppliers and 
                            service providers. | 
                         
                         
                          | Advising 
                            the Responsible Officer, Corporate Responsibility Officer, 
                            and employees and agents about professional ethics, 
                            compliance and social responsibility issues, most 
                            often seen in hospitals, ("Professional Ethics 
                            Council")  | 
                          An 
                            SME can conduct regular meetings of all or representative 
                            professionals, perhaps 30-60 minutes, once a month, 
                            to discuss enterprise core beliefs, standards, procedures, 
                            and expectations on current professional ethics, compliance, 
                            and social responsibility issues. A medium enterprise, 
                            especially one with multiple locations, can appoint 
                            members to such a council, but meet regularly by telephone. 
                            An SME can form or join a business association to 
                            develop training materials and provide a forum to 
                            discuss current professional ethics, compliance, and 
                            social responsibility issues, problems, and solutions. 
                            A college, university, or business development council 
                            can host a forum for SMEs. A large enterprise might 
                            host or sponsor a forum for its suppliers and service 
                            providers. | 
                         
                         
                          | Individuals 
                            at various levels of the enterprise who link a central 
                            ethics office with the field ("Business Conduct 
                            Representatives")  | 
                          For 
                            the SME, these may be respected, knowledgeable staff 
                            members at its various levels or locations, who have 
                            the right to communicate directly with the Owner/Owner-representatives, 
                            Responsible Officer, or Corporate Responsibility Officer on 
                            responsible business conduct issues: ethics, compliance, 
                            and social responsibility. These Business Conduct 
                            Representatives can also conduct responsible Business 
                            Conduct training and education and assist in program 
                            evaluation at local levels. | 
                         
                         
                          | Related 
                            executive and department functions, such as the Chief 
                            Financial Officer; Legal Counsel; Human Resources; 
                            Internal Audit; Environmental, Health and Safety; 
                            government procurement; and Investor Relations  | 
                          The 
                            SME often uses trusted, independent professionals 
                            to perform many of these functions. If so, they should 
                            participate in enterprise responsible business conduct 
                            training programs and, where practicable, its discussions 
                            of current ethics, compliance, and social responsibility 
                            issues. These independent professionals can form their 
                            own independent forums to discuss current ethics, 
                            compliance, and social responsibility issues. They 
                            may also be engaged to advise SME owners and managers 
                            on how to design and implement a Corporate Responsibility Program 
                            using this Manual and other resources. Provided they 
                            respect the confidences and proprietary information 
                            of each SME, they can amortize the cost of providing 
                            these services over multiple clients. | 
                         
                         
                          | The 
                            individual responsibility of every employee and agent 
                            of the enterprise to abide by the standards and procedures 
                            and strive to meet reasonable stakeholder expectations 
                             | 
                          Individual 
                            responsibility of employees and agents applies to 
                            all enterprises regardless of size. In the SME, it 
                            may be difficult for employees to seek advice or report 
                            concerns confidentially and anonymously. Owners and 
                            managers of SMEs must work to develop an organizational 
                            culture where employees and agents are able to speak 
                            up confidently and safely. | 
                         
                         
                          | Other 
                            stakeholders, including owners/investors and suppliers/service 
                            providers | 
                          The 
                            individual responsibility of every stakeholder to 
                            recognize the contribution/impact he or she makes/has 
                            by operating effectively, efficiently and responsibly 
                            within a market-oriented legal and ethical framework 
                            of choice and action and contributing to the development 
                            of individual human potential and social capital. 
                            See, e.g.,  | 
                         
                       
                      
                     
                      
                     
                    
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