Ethics and Compliance Program Implementation An Overview

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 • Continue to Advertise Program

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 company’s 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, EH&S) 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