Question: What are the elements of an effective ethics or envi- ronmental compliance program? How would you develop an ethics or environmental compliance program that would

What are the elements of an effective ethics or envi- ronmental compliance program? How would you develop an ethics or environmental compliance program that would satisfy the dictates of the federal sentencing guide lines? See Paul E. Fiorelli, "Fine Reduction Through Effective Ethics Program," 56 Albany Law Review 403 (1992); Paul E. Fiorelli, "The Environmental Sentencing Guidelines for Business Organizations." 22 Boston College Environmental Affairs Law Review 481 (1995).

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