effective controls. i look forward to that time as we move to the next level. 3. developing the methodology to assess effectiveness i mentioned earlier one of the promising new tools to assess the effectiveness of ethics and compliance programs, and that is the pei, the program effectiveness index. the excellent report by the ethics resource center, the federal sentencing guidelines for organizations at twenty years, has drawn attention to standards for assessing program effectiveness. the report states : “ altogether, the lack of assessment standards and guidance on how the quality of a compliance / ethics program should influence the outcome of a matter create the impression, validated by the [ ethics resource center ] and conference board studies... that too many judgments are being made inside a black box. ” 2 while we seem to be on the cusp of a number of promising indicators, like the pei, the truth is that we are not there yet. we simply do not have a tool that will give us an accurate and reliable measure of program effectiveness. instead, we have a situation where enforcers ( including those agencies with civil enforcement authority, such as the banking agencies ) tend to be result oriented. when we see that a particular organization has experienced a major compliance failure, we tend to view the failure as evidence of the ineffectiveness of the ethics resource center, the federal sentencing guidelines for organizations at twenty years at 51 ( 2012 ). bis central bankers ’ speeches ethics and compliance program. we reason backward, “ if the program were effective, this would not have happened. ” i think this is natural and understandable for the enforcement community, but it is not necessarily good policy. to borrow an observation from senator ted kennedy concerning the federal sentencing guidelines, this creates “ a risk that companies without substantial compliance programs will get a free ride, and those with strong programs will not receive the credit that they deserve. ” 3 alternatively, if there were a reliable and acceptable measure of program effectiveness, this kind of backward reasoning would be replaced by reliance on the effective measure. institutions could use the measure when making arguments for leniency, again assuming that the measure demonstrated that their programs were effective. it might, of course, show just the opposite. and there are other, perhaps even more important, benefits. if an industry and its regulators came to have great confidence in a particular effectiveness measure, this might provide a foundation for building a program that could be used to on - board risk. put differently, a particular organization could have confidence that its ethics and compliance program

the image of a suone symbolises the treatment and distribution of water – a major component of switzerland ’ s humanitarian and development aid effort. the key motif also plays an important role on the security strip, which features a network of waterways over the map of switzerland, together with a list of the country ’ s longest rivers. the remaining security features, such as the transparent swiss cross or the shimmering globe, are the same as those on all denominations of the new series – you will already be familiar with these. as with the other denominations, we are once again providing information in print and online, and we have of course updated our ‘ swiss banknotes ’ app. the new 100 - franc note will be issued starting next thursday, 12 september 2019, at our counters in berne and zurich and at the snb ’ s agencies. for logistical reasons, it will take a few days before the new notes are available country - wide. and now, having unveiled the new 100 - franc note, i ’ d like to show you the entire set. here it is : the complete ninth series, inspired by ‘ the many facets of switzerland ’. the vibrant colours and the aesthetically pleasing and intricate design of the series are particularly striking. switzerland ’ s many facets are showcased using core design elements such as the hand, the globe, a swiss location and an object, which are easily recognisable and recur throughout the banknote series. the theme of each note is illustrated via a hand gesture. on the 50 - franc note, the hand is holding a dandelion, whose seeds are carried away on the wind. on the 10 - franc note, a conductor ’ s hand sets the tempo for the orchestra. the shimmering globe reflects how switzerland sees itself as part of an interconnected world. in the sequence of notes from 1000 francs to 10 francs, the earth rotates once on its axis and passes through one full day. the places depicted on the back of the notes are emblematic of various locations in switzerland. together, the six notes illustrate the diversity of our country. the object depicted is linked to each note ’ s key motif. on the 20 - franc note, the object is a butterfly, and on the 200 - franc, a particle collision. the key motifs of the six notes are time, light, wind, water, matter and language. as i mentioned earlier, the security features are the same for all denominations. i hope