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Aligning Ethics Communication & Training With Business Priorities and Compliance Risks. Willow Misty Parks Graduate Assistant Anderson School of Management University of New Mexico Albuquerque, NM. Why Align?.
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Aligning Ethics Communication & Training With Business Priorities and Compliance Risks Willow Misty Parks Graduate Assistant Anderson School of Management University of New Mexico Albuquerque, NM
Why Align? • Why Align Your Ethics & Compliance Training and Awareness with Business Priorities • Protect your company against the risks that could have the greatest impact on your business success • These business priorities (and risks) will change over time and your ethics & compliance training and communications should adapt • Mitigates overall risk by prioritizing resources to largest and most relevant risks • Can help to improve senior business leader sponsorship and support • Drives more effective and focused training that employees can readily relate to • Helps improve employee interest and knowledge retention • Enables ability to further increase awareness through E&C awareness “campaigns” throughout year consistent with business initiatives
Content & Timing • Ethics & Compliance Awareness Approach: Key Points for Content and Timing • Topic identification and prioritization based on business need and risk • Development of topical campaigns, combining: • Required training • Awareness • Development of annual calendar • Tracking
Threshold For Topics • Minimum threshold for a mandatory curriculum • Topics Must: • Be aimed at a widespread, relevant audience, and • Reinforce a legal, compliance or ethical behavior • Emphasize policies or Code of Business Ethics and/or • Protect company from non-compliant illegal activity
Identifying & Selecting Topics • Look at Changes: • New policies • Incidents • Development changes • Identify what is important to the company • Determine whether to train or campaign information? • Data driven • Consistent and Flexible
How to Align Topics & Needs • Prioritization Factors • Leadership drive • Subject matter experts (SMEs) to identify potential exposures, understand any recent changes in the regulatory environment and emerging risk, identify incidents and the legal requirement or desirability to train • Trending input from corporate investigations, human resources, litigation, global compliance monitoring and other relevant teams who can provide data and insights • Aging data from E&C organization and SMEs
Benefits of This Approach • A consistent, but flexible, year-on-year approach that can be applied across initiatives. • Using comprehensive data to target the highest priorities and risks to the business. • Can identify additional compliance topics for training and awareness consideration. • Training and reinforcing communications focused on business priorities.
Steps of Approach • Once we apply the prioritization factors, we do a little math • Once scored, we prioritize each topic to determine which require increased awareness, and those for which we only need to maintain awareness. • Create an Ethics and Compliance Curriculum Plan
Training Schedule: Surround Sound • Develop “Topical Campaigns” • Set in an annual calendar • Reinforce knowledge • Interest related • Multiple years • Tracking knowledge capture
Training Schedule: Surround Sound • After Determining Training Schedule, Develop Communications Strategy: Call it a Surround Sound Approach • Holistic approach tied to prioritization • Individual communications plans for training topics • Working across initiatives – surround sound approach – all reflecting key message
Track Results • Tracking results help with continuous improvement and establish priorities for upcoming year. • Best practices for increasing knowledge and awareness: consequence (e.g., performance management) • Assess understanding and learning increases: - Use of pre-tests - Analysis of questions to ethics mailbox and review of reported allegations • Correlate training and awareness efforts with employee activities • e.g., Visits to Code of Business Ethics site / individual web pages • Visits to specifically relevant policies and compliance portals, etc. • Conduct ethical perception surveys