1. First of all, attitude is everything, as they say, and to continue and/or cover up corruption in your organization--especially widespread and endemic corruption that has been in your organization for years and would be much more difficult (for financial and other reasons) to end than to continue--you must have the correct corporate attitude to make your corrupt activities have the most positive impact on the bottom line and to keep them secret to the extent possible for them to continue. This is not the image in your public image ad campaigns. This is the real attitude of your corporation, and it must come from your corporate headquarters and flow down through the organization and be made known to those outside the company that may (through ethical "defects") feel obligated to report corruption within your company they have learned about to any of the the local, state, or federal government agencies. It is the "attitude" your own "in the know" employees know, and anyone daring to expose your corruption from within the company or from without must be made to know and fear. The most preferred attitude in this regard for your corporation to have would be extreme arrogance. Arrogance lets those people that might otherwise dare to expose your corruption know that you do not care what the public or what the government really knows about your corporation's corruption. They know through your arrogant "behind the scenes" corporate attitude and related actions that you will roll right over anyone who gets in the way of any sort of corrupt activity your corporation chooses to engage in. Make people fear the size and power of your organization to make their lives miserable if they so much as think of holding you accountable for any illegal or unethical action you are engaged in or are contemplating engaging in. They will get the message if your corporation projects this sort of attitude successfully. Boeing is a good example in this regard. As noted elsewhere on this site, a Corporate Investigations Manager told me (in an interview with him the day after I was released from jail in my own personal lesson of Boeing's arrogance) that "Boeing is the most arrogant company on the face of the planet." I, personally, because of my intimate experience with Boeing, agree with his matter of factly stated statement. While, per this Boeing manager, Boeing has the #1 position locked up, your corporation could follow this example and set a goal to become the #2 most arrogant company on face of the planet. Arrogance has a key benefit for those organizations wanting to continue or to perpetrate corruption. As I read a former Congressman had sagely said--"arrogance breeds corruption." So, arrogance will not only protect your ability to perform your fraudulent action of choice, that attitude will also foster the corruption you want in your organization, for potentially significant benefits to the bottom line if you succeed in getting away with your fraud of choice.

2. Don't let past negative quarters of financial results when caught and fined for illegal actions deter you from your continuing arrogance and corruption. Just because you were caught on some of the more minor acts of corruption of your company does not mean you have to abandon all corrupt activities within your organization. To do so would have long term negative financial impacts. Even politicians that railed against and even exposed your corruption need not be a deterent. During election seasons and times of weightier issues such as war, your corrupt organization can effectively "skate under the radar" of these same politicians that were pains in your organization's "corrupt backside" before, even if people report some of your remaining and even vastly more serious corrupt activities than you were caught engaging in directly to them. They cannot respond to every report of corporate corruption they get, and they also don't want to be seen as having a vendetta against you, especially if you are a sufficiently powerful corporation and it is election season again. They may have ended a minute part of your corrupt activities in the past, but they may not want to take the risk of taking away from their successful record in the public eye by risking losing the next battle to expose and end reported corruption in your huge and powerful corporation.

3. Become a duopoly in your markets of choice. This will make it impossible for politicians and government agencies to put you and your endemic corrupt activities out of business. If they have a need for your products and services, they will not be able to apply the necessary sanctions that will motivate you to end your corruption and therefore protect the public and military personnel from your corruption. Politicians can then hide behind the bogus reason that contracts with your corrupt organization cannot be effectively ended due to the need for your products and services for national and economic security reasons to excuse them from having to do the tough work of fielding and responding to effectively the numerous reports of corruption such politicians receive about your corpration's corrupt activities by those do-gooders who delude themselves that they can have an effect in ending some part of you enterprise's corrupt activities by reporting them to the seemingly appropriate politician or government agency. This I saw in some of the questions/comments of some of the few politicians who showed up at the 8/1/06 Boeing Tanker/EELV Global Settlement Agreement hearing. Of course such reasons to not go after corrupt corporations are false--the government can hold a company--even one of a duopoly of companies--accountable for their illegal actions while still holding the company to their contract committments to deliver conforming hardware and services. The government can strip such a company (via fines for their actions) of all of their profits for decades to come or until they choose to really end corruption as a primary tool to meet internal financial goals. In addition they can throw any number of corrupt managers of such a corporation in prison (after a fair trial, of course) for any length of time without harming the companies ability to deliver conforming and safe products until managers who get the message that corruption in that company will not be tolerated--truly ethical management--is put in place at the company replacing the imprisoned executives and managers. But that would require a level of oversight by the government that it may not be willing or able to perform because of the endemic and vast nature of your corruption, much to your corrupt company's benefit, of course.

4. Whatever you do, do not start a so called "ethics program" at your company in an attempt to make it seem publicly like you are an ethical company despite your continuing use of massive levels of unethical and illegal acts to meet financial and other goals. While a good PR move, such programs will be expensive and non-value added at a company as corrupt as yours. This is because you dare not let most employees know of your official and unwritten policy of using whatever method, legal or not, best maximizes your bottom line because, in an organization of your size, even the very small percentage of employees that are "ethically defective" (from your corrupt organization's perspective) and would report this fraud to the relevant investigative agency of the government would be a large number of such reports indeed, each with some miniscule risk to your corporation's continued unbridled corrupt activities. These risks and the legal and administrative costs of ending such valid reports of your corporation's wrongdoing by any means makes letting everyone in your organization know about your unwritten policy to use illegal and unethical means to attain business goals a non starter. Therefore, since most employees cannot be told the real way your company does business, such an ethics program would receive massive numbers of reports of the unethical conduct you wish to foster in your company from those employees who actually delude themselves into thinking you want them to follow written but just for PR purposes policies for employees to report unethical and/or illegal conduct at the company if they see such behavior. And even though such a program would be set up to ensure it does not threaten the fraud you wish to engage in by ensuring such reported activities are always dubbed "unsubstantiated" after a psuedo-investigation of the report, such a ethics program would entail significant costs just due to the number of reports from employees who delude themselves that the company is serious about the ethics program--costs that would subtract from your company's all important bottom line and therefore from the potential value of your stock grants and options. 

5. However, if you are required to set up some kind of ethics program as promised corrective action to a government entity after having the misfortune of being caught by them for one of your many acts of corruption, you will need to set an ethics program befitting your company (a corrupt one). It is better and much less expensive to set up an ethics program than it would be to have real corrective action that may actually end your use of unethical and illegal acts to maximize the bottom line, such as significant fines that would wipe a whole year's profits off the books and cause your stock price to plummet for years to come. By all means "promise" to set up an ethics program as an alternative to jail sentences for most of the executive management involved in the corruption (especially yourself) and such significant fines, and hope the government "bites" on your proposal, no matter how many times you have been caught breaking such promises in the past. Just carefully avoid "promising" to implement an effective one, if at all possible. A model program would protect your unethical management by deeming the vast majority of ethical complaints against management as "unsubstantiated," no matter how much evidence the person or persons reporting the unethical conduct have of the manager's misconduct. A good standard to apply is to require a video or audio or email trail in order to substatiate such a complaint. As video and audio recording without approval inside most companies is prohibited by company policy and/or privacy laws, that only leaves email as a threat to your corrupt management, and your managers can be warned not to document your company's questionably if not illegal conduct in email, and be told to delete any possible incriminating email ASAP. Of course, you can substantiate claims against non-management personnel as you wish, as those personnel are expendable, and you can use those substantiated claims to give the appearance to the government that your ethics program is working, should they audit the program. A good model for an ethics program for your company can be found here: