compliance training - can you get it right? · novartis intro a world-leading healthcare company...
TRANSCRIPT
Dr. Britta Lüscher, Director Compliance, Novartis
LexisNexis Compliance Solutions Day, München
June 2015
Compliance Training - Can you get it right?
Novartis Intro a world-leading healthcare company
2014 USD billion
Net sales: 58.0
Net income: 10.3
R&D investment: 9.9
Key figures
Leading market position
One of 25 largest companies by market capitalization
Among most respected companies globally
Sales by region 2014
Canada/
Latin America
US
Europe Asia/Africa/
Australasia 37%
32%
21%
10%
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 4
Novartis Intro Our organization is poised to lead in these segments
Novartis Institutes for BioMedical Research
(NIBR)
Novartis Business Services
(NBS)
No.2 generic medicines
company worldwide
One of the world’s largest
pharmaceutical companies
No.1 eye care
company worldwide
Alcon Sandoz Novartis Pharmaceuticals
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 5
In 2014 Novartis products
reached more than
1 billion
patients
To be the world's most
respected and successful
healthcare company
Our Vision √
To care and cure
Our Mission √
Novartis Intro Always with a focus on patients
Science-based innovation
Better patient outcomes
Growing areas of healthcare
Our Strategy √
Innovation
Quality
Collaboration
Performance
Courage
Integrity
Our Values √
To be the world's most
respected and successful
healthcare company
Our Vision √
To care and cure
Our Mission √
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 6
Novartis Intro Our achievements are gaining recognition
#2 pharmaceutical
company in Fortune’s
World's Most Admired
Companies
Novartis in top 3 for
11th consecutive year
#4 in the Access to
Medicine Foundation’s
Access to Medicine
Index
Top 100 Global
Innovator
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 7
Novartis Compliance Program
Controls &
reporting
Whistleblower
line & audits
Policy
framework
Objectives
and annual
performance
Blogs
Town halls
Intranet
Training
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 8
Traditionally the objective of
the Compliance Training has
been to establish a legal
defense
World has evolved.
The new priority for compliance
training is building an ethical
culture
New challenges aroused
► “Check-the-box” training is now not
just outmoded but also puts the new
objective at a risk by increasing
employee´s cynicism
► High quality, engaging training must
become the norm (not the exception)
Compliance Training... What for?
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 9
56%
54%
42%
41%
31%
23%
23%
19%
18%
17%
35%
42%
44%
46%
54%
67%
59%
57%
46%
62%
10%
6%
14%
13%
15%
10%
18%
24%
36%
22%
Significant Challenge
Not a Challenge
Moderate Challenge
Limited hours available for training
Measuring Effectiveness
Not enough budget
Difficulty covering all of the topics important to our organization
Training content is growing old/stale
Training not effective at changing attitudes or behavior
Training content is low quality / unengaging
Training content is not relevant to our audience
Difficulty tracking and reporting training completion
Employees respond negatively to training
Data Source: NAVEX Global’s 2014 Ethics and Compliance Training
Benchmark Report
Seat time and budget constraints are considered top challenges
for compliance training nowadays
1
2
3
10
9
8
7
6
5
4
Challenges & concerns
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 10
19%
64%
10% 5% 3%
21%
69%
9% 2% 1%
57%
36%
4% 1% 2%
55% 41%
3% 1% 0% 7%
76%
14% 3% 1%
Median = 2.5 Courses
Median = 2.5 hours Median = 0 hours
Median = 0 Courses Median = 1.5 Courses
6%
69%
13% 8% 5%
Median = 2 hours
Challenges & concerns
Training
Hours (annual)
Training
Courses (annual)
Median for Middle Managers and Non Managers is 2.5 hours / 2.5
courses.
Compliance Training to Third Parties at a risk
0 Courses 1 – 5 Courses 6 – 10 Courses 11 – 15 Courses 16 or more Courses
0 Hours 1 – 5 Hours 6 – 10 Hours 11 – 25 Hours 25 plus Hours
Senior Leaders Middle & Non Managers Third Parties
Data Source: NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 11
Q1 Q2 Q3 Q4
Max: 4 Short Courses / Refreshers (~10 min each)
Max: 4 Full courses (~20-30 min each)
Code of
Conduct AB
Su
mm
er
Bre
ak
Cu
t O
ff:
No
Ro
llo
uts
Adverse
Events
CoI
1 2 3
4
Onboarding Course for ALL New hires (internals & externals)
2015 Novartis Compliance e-Training Curriculum
Strategic Curriculum Design
We don’t fill our slots just because we have them
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 12
Training Topics
73%
53%
47%
46%
45%
42%
40%
36%
34%
25%
25%
22%
22%
27%
38%
17%
38%
37%
44%
26%
32%
44%
26%
63%
5%
20%
15%
37%
17%
21%
16%
38%
34%
31%
49%
15%
All employees
Course not offered
Some employees
Code of Conduct
Recognizing and reporting misconduct
Information security awareness
Anti-retaliation
Data Privacy
Conflict of Interest
Gifts and Entertainment
Ethical Decision Making
Handling and escalating allegations
Fraud Awareness
Data Source: Benchmarking analysis by CEB (Compliance Executive Board)
“Code of Conduct” and the “Recognizing and reporting
misconduct” are courses most frequently required for all employees
Social Media Use
Anti-Corruption or Anti-Bribery
1
2
Despite the significant
legal & reputational risk
that Anti-Bribery area
poses to an organization, it
is ranked surprisingly low.
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 13
Training Format
71%
68%
57%
48%
47%
45%
45%
36%
33%
31%
29%
26%
15%
11%
7%
6%
2%
Online Training
Live Training
Certification System
Print Resources (e.g. Handbooks)
Intranet
Posters
Informal meetings
Newsletters
Webinars
Manager Discussion Materias
Short Training Vignettes
Wallet Cards
Digitak Resources (e.g. e-books)
Social Media
Direct Mail
Other
Data Source: NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report
Using wide variety of
formats to reach learners
has proven to be more
effective creating higher
impact and thus delivering
better results
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 14
• Central approach : Capacity and Consistency
Covers huge audience in remote locations and ensures that the message is communicated in a
consistent fashion.
• 24/7 Accessibility
The course can be accessed anytime, anywhere.
• Improved Pedagogy
Gamification enhances learner engagement and improves retention
• Speed, Time and Money Savings
Reduces time away from the workplace & eliminates the need for travel. 1 investment for all your
employees & no training material costs, can be achieved at defined timelines
• Flexible
Gives employees the freedom to learn at their own convenience and at a pace that is right for them.
• Consolidated reporting
Element to establish legal defense and to demonstrate compliance program’s effectiveness
Benefits of e-Training
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 15
• 100% relevant content
• Customized to meet organization´s unique needs
• Reflect your corporate style and philosophies
• Enhances learner engagement (direct relation to their jobs)
• Full Ownership: Full rights to use and edit. Does not need user
licenses
Benefits of bespoke content
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 16
Anti-Bribery
Information
Management
Fair Competition
Conflict of
Interest
2012 2013 2014 2015
Novartis Communications Campaigns Courses and communication are branded
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 17
This approach enables your organization to provide appropriate training across the organization
based on factors such as role, geography and their level of exposure to a particular risk
High risk roles
Job in the crosshair of a particular
risk. Significant impact to the org.
if risk is mishandled
Medium risk roles
Jobs facing the risk on a regular
basis. Moderate impact to the org.
if risk is mishandled
Low risk roles
Low likelihood of the job facing the
risk. Low impact to the org. if the
risk is mishandled
• Frequently repeated training
• Several formats (online, face
to face, campaigns, etc)
• Training refreshed
periodically
• Online training, campaigns
• Regular Education
• Campaigns, email, newsletter
Risk-based approach
Risk-based approach, goes beyond simple „check box‟ compliance by
focusing training efforts to maximize the return on the investment.
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 18
E-Training evolution at Novartis
2012 2013 2014 2015
• Bespoke Novartis courses
• Own content, look & feel
• Use of real cases
• «Action mazes» shorter content for learners selecting compliant answers
• In-course profiling
• Segmentation by Function
• New Hire onboarding: 1st Bundle course
• Real-time reporting (24/7)
• Consistently high completion rates
• First online training for New External Contractors
• Increased use of «interactivity»
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 19
Compliance Training Trends
Increase number of trainings to cover more risk areas that
s are currently uncovered 1
Additional Emphasis on Middle Manager training 2
Collaborative Learning (peer-to-peer, group discussion, problem solving etc.) 3
Training Third Parties 4
Gamification 5
Data Source: Selected trends from NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 20
Compliance Training Trends (cont.)
Trend ranked n° 1: Increase number of trainings to
cover more risk areas that are currently uncovered
Given the constraints of seat time and budget, for
organization adding courses will mean getting creative
SMART options:
• Risk-based approach
• Blended courses: use different format to reach learns
• Bundled courses: combine several topics in one
• Short courses
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 21
Training Quality
88%
81%
80%
77%
64%
62%
42%
37%
10%
16%
17%
20%
32%
30%
44%
33%
2%
3%
3%
3%
4%
8%
14%
30%
Significant Importance
Not Important
Moderate Importance
Look & Feel, Engaging and Interactive
Fresh and Contemporary Content
Customized Options
Reputation of Vendor and Service
Endorsement of Respected Regulatory Bodies
Training Provider Learning Management System (LMS)
Mobile Enabled
Content Translated into other languages
High-quality training is seen as superior when is credible, fresh and
relevant.
Data Source: NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 22
Measuring Effectiveness
Ethics and Compliance training is supposed to prevent
problems from happening so... How can one quantify that
which hasn't happened?
While the most common and frequently used method is
measuring completion rates, it only measures successful
training deployment, not effectiveness.
To improve measurements is key that organizations establish a
robust set of KPIs for training programs which can include
completion rates but also other methods like focus groups,
surveys, litigation data, changes in helpline‟s reports etc.
| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 23