Aligning Ethics Communication & Training

With Business Priorities and Compliance Risks

Willow Misty ParksGraduate Assistant

Anderson School of ManagementUniversity of New Mexico

Albuquerque, NM

• 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

Why Align?

• 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

Content & Timing

• 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

Threshold For 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

Identifying & Selecting Topics

• 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

How to Align Topics & Needs

• 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.

Benefits of This 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

Steps of Approach

• 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

Training Schedule: Surround Sound

• 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

Track Results