Ethics and Compliance Program Implementation

1
Ethics and Compliance Program Implementation An
Overview
2
Approach to Ethics/Compliance Awareness and
Training Must Be Programmatic

• Lay Proper Groundwork
• Understand Technical, Cultural, Geographic and
  Other Issues
• Obtain Buy In and Support
• Send Clear Message Regarding Requirements
• Continue to Manage and Refine Program After
  Rollout

3
Establishing Your Program

• Set Up the Program for Success
• Define Program Goals
• Analyze Cultural, Geographical and Technical
  Issues that Affect Rollout
• Establish Implementation and Program Management
  Plan
• Coordinate Involvement of Appropriate Company
  Representatives
• Define Curricula for Employees
• Manage Weekly Status Meetings and To Do Lists to
  Keep Rollout on Track

4
Ongoing Plan Management

• Ensure Continuing Program Success
• Evaluate Usage Data
• Analyze Program Success and Failures to Refine
  Program Management Plan
• Attend Management Meetings, Seminars, Open
  Houses and Other Events to Market Program
• Provide Ongoing Plan Management (site changes,
  new enhancements, training, etc.)

5
Typical Implementation Steps

• Develop Program Management Plan
• Define Program Goals
• Identify Key Players
• Make Key Decisions
• Customize Site
• Incorporate Company Look and Feel
• Identify Tracking/Reporting Levels
• Design Completion Message(s) and Certificate
• Prepare Rollout Plan and Marketing Campaign
• Develop Rollout Strategy
• Identify Marketing Media
• Customize Site Marketing Materials
• Execute Rollout Campaign
• Meet with Management
• Advertise Site
• Hold Employee Open Houses
• Manage Program
• Review Site Usage
• Follow Through On Mandatory Requirements

6
Key Program Decisions

• Overall Plan Issues
• Who will be on your Steering Committee to
  manage the rollout and plan after rollout?
• Module selection Which modules will be mandatory
  and for whom?
• What are the companys goals for the program
  (percentage of employee base, modules completed,
  time frame, divisions, etc.)?
• Are there any impediments to employees taking
  modules that need to be addressed (lack of
  computers, disabilities, language, etc.)?

7
Key Program Decisions

• Customization Issues
•  What employee data should be bulk loaded in
  order to manage the program and provide
  meaningful reporting?
• Will modules be pre-assigned through bulk load or
  will site curriculum generator be used, or both?
• What level of tracking and reporting will be
  selected?
•  Will bulletins be written in any modules? If
  so, who will write them?

8
Key Program Decisions

• Rollout Issues
•  What is the tone of the message you want to send
  as you advertise the program?
• What communication methods will best reach your
  user base?
• Will the rollout be done in phases or all
  employees at one time?
• What is the best way to communicate the program
  to management in order to obtain their buy in and
  support.
• From whom will the message to employees come?

9
Mandatory Requirement Issues

•  Will mandatory requirements be imposed?
• If so, are people willing to carry them out?
• Which courses will be mandatory?
• For whom will those courses be mandatory?
• During what time frame must the courses be taken?
• What are the consequences of not taking courses?
• effect on raises, bonuses, evaluations,
  promotions
• limitation on activities

10
Mandatory Requirement Issues

• Who will manage the mandatory requirements?
• human resources
• legal/compliance
• individual managers
• Will managers be evaluated based on the
  compliance of their direct reports?

11
Mandatory Requirement Issues

• How will the mandatory message be relayed to
  employees?
• How will the mandatory requirements be imposed on
  new employees
• part of orientation process
• completion required in order to receive e-mail
  address, network logon, company events, other
  privileges?

12
Best Practices for Program Management

• Hold weekly meetings/calls to keep rollout plan
  on track
• Roll out custom Code of Conduct with program
• Centralized decision-making facilitates
  introduction of compliance initiatives
• Utilizing representatives of several departments
  (HR, Communications, IT, EHS) facilitates
  development of a successful rollout and
  management plan

13
Best Practices for Program Management

• Gaining acceptance of initiatives from managers
  across company facilitates acceptance of program
  by all employees
• Making managers responsible for the compliance of
  their reports helps ensure program success
• Mandatory requirements help set tone for strong
  compliance initiative and improve employee
  participation
• Following through on mandatory requirements
  ensures success

14
Best Practices for Program Management

• Use of carrot in addition to stick help make
  ethical and compliance awareness part of company
  culture.
• Conducting open houses at key locations to
  introduce site improves acceptance and
  utilization by all employees
• On-going plan management and marketing are key to
  a successful program