Mark Dorosz VP of Compliance Learning New York, USA Matt Plass Chief Learning Officer Brighton, UK How to design training for AB 2053 California Anti- Harassment Legislation
Aug 07, 2015
Mark DoroszVP of Compliance
LearningNew York, USA
Matt PlassChief Learning
OfficerBrighton, UK
How to design training for
AB 2053
California Anti-
Harassment Legislation
2-hours of workplace harassment training to be completed every two years by all people supervisors
Newly hired or promoted managers must be trained within 6 months
Training must be interactive and include “practical examples”
California law is commonly held up as the national standard, allows the 2-hour seat time to be broken into shorter and more meaningful learning chunks
What does the California law require?
Addition of requirement to train on “abusive conduct”, as well as unlawful harassment
You need to distinguish between “unlawful harassment” and “abusive conduct”
There is no guideline as to how much of the 2-hours should be devoted to one or the other
What changed on 01 Jan 2015?
Connecticut – 2 hours on sexual harassment within 6 months of hiring
Maine – requires all employees to take sexual harassment training, no guide on duration
Other states where Harassment training requirements for certain types of employee e.g. employees of the State:FloridaIllinoisIowaMichiganNevadaNew MexicoNorth Carolina
OklahomaPennsylvaniaTennessee TexasUtahWashington
Are there similar laws in other states?
We have a captive audience for 2 hours
How can we make the best use of this time?
Attestation
Impact
Investigation
Culture
Assembly
5 ways to make a difference in your 120 minutes of training
Idea #1: Assembly
What is Harassment and Discrimination?Impacts of DiscriminationTypes of DiscriminationSexual Harassment Preventing Workplace BullyingRetaliationProtected GroupsIntent vs. PerceptionSocial Media Risks for A-H&D
What is Workplace Conduct?Business EthicsInclusive WorkplaceInclusive ManagerViolence in the WorkplaceSubstance MisuseGifts & EntertainmentConflicts of InterestDiversity
What is important this year?
Assembly
Idea #2: Culture
1. Speak with authority
2. Facilitate difficult conversations
3. Promote the culture of compliance
4. Model behavior
5. Create a speak-up environment
Manager Focus
Break content down into short, digestible chunks
Focus on behaviour change
Teach values and principles to abide by
Align training with your workplace culture
Make learners complete 2 hours in one sitting
Teach the specifics of the law – information overload!
Exclude senior management from the development process
View it as a box-checking exercise
Encourage proactive strategies to anticipate compliance breaches Culture is not a set of
rules and regulations
DO DON’T
Idea #3: Investigation
1. Policy hunt
2. Investigate good ethical behavior
3. Explore corporate policies
4. Investigate regional and role-based differences
5. Uncover war-stories
Investigation
Idea #4: Impact
Present new concepts
Test for understanding
Practice to make it real
Attest to readiness
Our Instructional Model
1. 83% say yes to video!*
2. The inside track
3. Gone in 60 seconds
4. Tips from the top
5. Legitimacy with audience
*trainingzone.co.uk
Animations/Videos
1. Your people, your words
2. Your policies
3. I’m not a criminal!
4. Explore the grey areas
5. Play safe
Customization
Idea #5: Attestation
1. Are you ready?
2. Behavior checklist
3. Take responsibility for my actions
4. Award completion
5. Customized statements
Attestation
What is IS doing?
What is Interactive Services doing?
Anti-Harassment And Discrimination (A-H & D)
What is Harassment and Discrimination?
Impacts of Discrimination
Types of Discrimination
Sexual Harassment
Preventing Workplace Bullying
Retaliation
Protected Groups
Intent vs. Perception
Social Media Risks for A-H&D
“Got It” Taking Action on A-H&D
Workplace Conduct
What is Workplace Conduct?
Business Ethics
Inclusive Workplace
Inclusive Manager
Violence in the Workplace
Substance Misuse
Gifts & Entertainment
Conflicts of Interest
Diversity
“Got It” Taking Action on Workplace Conduct
1. Choose topics from existing library
2. Identify which ones are ready to go and which ones you want to customize
3. Workshop customization with partner and SME team
4. Partner implements customization
5. Launch
Here’s how Interactive Services is doing it
Customizing Your CLC Solution
Pick from 60+ Topics
4 weeks5 weeks
6 weeksRapidSmart
Managed
Build Your Topics Branding
Policy links
Splash screens
Add new screens
Add your imagery
Change the script
CLC Workshop
<Model Text>
We’re Counting on You
Our global clients, stakeholders, and investors count on us to conduct business with the highest ethical standards.
The good news is that at Gallus Retail we believe it’s simple to stay on the right side of Insider Trading Policy. Janine Smith, our Chief Compliance Officer, advises three simple steps:
If you see a breach of standards, or realize you’ve made a mistake, speak up immediately.
If you’re not sure, consult the Insider Trading Policy.
If you’re still not sure, speak to your manager or contact the compliance helpline.
1 x 720p MP4 executive video message not to exceed 120 seconds
1 x Uncompressed JPEG, PNG or Tiff image at least 3000px by 2000px
Instructional Tips For Compliance OfficersThis screen helps learners make the connection between your firm’s Insider Trading policy and their personal responsibility. Keep the message simple, under 200 words and try to include three memorable steps every employee can take.
Sample Customization Worksheet <T1:S2>
Insider Trading
What is Insider Trading?
Consequences of Insider Trading
Material Non-Public Information
Tipping
"Designations, Restrictions & Trading Windows"
“Got It” Taking Action on Insider Trading
Anti-Money Laundering
What is Money Laundering?
Consequences of Money Laundering
Placement Layering, Integration
Tactics to Prevent Money Laundering
The Risk Lifecycle
Sanctions and Embargos
Internal Reporting for AML
“Got It” Taking Action on AML
Anti-Harassment And Discrimination
What is Harassment and Discrimination?
Impacts of Discrimination
Types of Discrimination
Sexual Harassment
Preventing Workplace Bullying
Retaliation
Protected Groups
Intent vs. Perception
Social Media Risks for Harassment & Discrimination
“Got It” Taking Action on Harassment & Discrimination
Workplace Conduct
What is Workplace Conduct?
Business Ethics
Inclusive Workplace
Inclusive Manager
Violence in the Workplace
Substance Misuse
Gifts & Entertainment
Conflicts of Interest
Diversity
“Got It” Taking Action on Workplace Conduct
Information Security
What is Information Security?
Consequences of an Information Security Breach
Email and Messaging
Welcome1 is not a Password
Secure Social Media
Secure Workstation
Secure Outside the Office
Social Engineering
“Got It” Taking Action on Info Security
Data Privacy
What is Data Privacy?
Protecting Personal Information
HIPAA Basics
Working with the Cloud
Storing Data
Disclosures
“Got It” Taking Action on Data Privacy
PCI DSS
What is PCI DSS?
Sensitive Data & Vulnerable Areas
Handling & Storing Data
Preventing Breaches
Got It! Taking Action on PCI DSS
Anti-Bribery & Corruption
What is Anti-Bribery & Corruption?
Consequences of Bribery & Corruption
Bribery & Corruption High Risk Activity
Cash, Gifts, Entertainment and In-Kind
Tactics to Prevent Bribery & Corruption
Books & Records
Politically Exposed Persons
Red Flag Locations
“Got It” Taking Action on A-B & C
Anti-Trust
What is Anti-Trust?
Dealing with Competitors
Dealing with Customers
Communication & Document Creation
Got It! Taking Action on Anti-Trust
Build Your Solution From 3 Libraries and 60 Essential Topics
LANGUAGE PACK (Arabic, French, German, Italian, Japanese, Standard Chinese, Polish, Portuguese, Russian & Spanish)
1. Culture is habit forming
2. Impact, preparing for tomorrow
3. Take responsibility through personal investigation
4. Mix and match what’s important to you
5. Attest with confidence
5 key points to remember….
Interactive Services will be running a series of short executive briefings for interested companies in April and May.
Please let us know if this you’d like us to arrange one specific to your firm.
What happens next?
Mark Dorosz ([email protected])VP, Compliance LearningNew York, USA
Matt Plass ([email protected])Chief Learning OfficerBrighton, UK
Neil Cullen ([email protected])Director, Compliance LearningNew York, USA