Despite limited budgets and unique organizational challenges, smaller companies face many of the same drivers with respect to implementing effective ethics and compliance programs as do large public companies. At the same time, smaller companies face additional challenges because the in-house counsel must wear multiple hats including lawyer, business advisor, price analyst, proposal developer, contract administrator, facility security officer-just to name a few. This program will offer a workplan and specific solutions for in-house counsel who must implement an effective ethics and compliance program with limited financial and staff resources, including a look at some of the conflicts when counsel also wears a business hat.