Ethics - cefli.org€¦ · COMPLIANCE & ETHICS FORUM FOR LIFE INSURERS Ethics Administration and Oversight of a Company's Code of Conduct or Ethics Program Educational Webinar

COMPLIANCE & ETHICS FORUM FOR LIFE INSURERS

Ethics Administration and Oversight of a Company's Code of Conduct or Ethics Program

Educational Webinar March 24, 2015

© CEFLI 2011. All Rights Reserved. March 24, 2015 • 2

CEFLI PREMIER PARTNERS ~ Leading the Way ~

Agenda. • CEFLI’s Antitrust Policy.

• Industry Perspective.

• Company Perspectives.


Presenters.

• Kathleen Edmond – Partner (Robins Kaplan)

• Pete Rock - Deputy Chief Compliance Officer (Knights of Columbus)

• Alayne Russom – Manager, Code of Conduct - Corporate Law (Thrivent Financial)

• Andrew Zembles - Assistant Vice President - Corporate Compliance (Pacific Life Insurance Company)


Our Webinars. • CEFLI is committed to presenting important and relevant topics to

the life insurance industry through our very popular Educational Webinar Series. These webinars will provide you with key regulatory, company and industry insights on emerging issues and functional compliance areas. They also will: – Provide you with regulatory interpretations and guidance.

– Present you with an overview of company challenges and leading practices.

– Offer opportunities to ask questions of regulators, company professionals and industry experts.

– Allow for a convenient and easy way for CEFLI members to use this educational forum to further supplement their compliance training.

– Point you to other valuable resource materials.


Today’s Session.

• Will review the key elements of establishing an effective ethics or code of conduct program.

• Will examine some examples of codes of conduct and ethics programs at member companies.

• Will discuss oversight and monitoring.

• Q+A.


Polling Question

• Has your company named a Chief Ethics Officer or a Chief Code of Conduct Officer?

© CEFLI 2015. All Rights Reserved. March 24, 2015• 7

Agenda

• What’s new for Ethics / Compliance

• Oversight of Your Program

• Staying Fresh and Relevant

• What's Next?

• Closing Thoughts


What’s new for Ethics / Compliance

• Heightened expectation of usable, relevant metrics related to Ethics Office effectiveness

• Risk based programs

• Focus on monitoring effectiveness

• Other disciplines have growing interest in areas previously thought to be domain of E&C


Oversight of your program

• Ongoing monitoring of controls and effectiveness

• Conducting compliance program audit

• Investigations, remediation, and lessons learned

• Effective use of – Complaints

– Consultations

– Listening

– Communication vehicles


Staying fresh and relevant

• Sharing real stories – One of the most effective ways of engaging employees and

teaching

– Raises the question of organizational appetite for transparency

• Know your business

• Learn from others in the same and different industries

• Critical assessment of your personal effectiveness in role


What's next for ethics / compliance?

• Regulation will continue to increase

• Seeing beyond the current issues

• Coordinating and maximizing efforts between ethics / compliance, internal audit, ERM, governance

• How do you plan for the future of the program within your organization?


Closing thoughts

• The field is moving and growing in new ways. We must have a strong foundation to program, but anticipate future needs keep the organization engaged.


Thank you~

Presented by Kathleen K. Edmond

Robins Kaplan LLP

612.349.8242

[email protected]

mailto:[email protected]

Polling Question 2

• Does your company have a Conflicts of Interest policy and, if so, does it apply to all employees?


Agenda

• History of the Code

• Publicizing the Code

• Monitoring Effectiveness of the Code


History of the Code

• Rolled out to employees in 2003

• Branded

• Name: It’s My Responsibility

• Logo: See above right

• Completely reimagined and reintroduced in 2011

• Available on PacificLife.com


Principles of Integrity

• Ethical Conduct

• Professional Conduct

• Protection and Proper Use of Information and Systems

• Compliance with Laws, Regulations, Policies, and Procedures



Publicizing the Code

• Compliance & Ethics Training and Awareness Program

• Premise: Keep the message in front of employees



• Annual IMR Training – Online

– Mandatory

– All employees





• Splash Messages – Articles

– Quizzes, games

– Fabulous prizes

– Not mandatory





• Corporate Compliance Website – Various resources

– Past articles

– Training scripts

– Meet the Team

– Managers’ Portal (coming soon)





• Code items and fun stuff – Cups

– Table tents

– Magnets





Monitoring Effectiveness

• Federal Sentencing Guidelines: Take reasonable steps to… – Ensure that the program is followed, including

monitoring and auditing

– Evaluate periodically the effectiveness of the program



• Look at: – Reported violations

– Audit results

– Market conduct exam results

– Industry practices and enforcement actions

– Eye on the road, ear to the ground



• Employee Compliance Survey – Measures employees’ perceptions about our

ethical culture

– Rates the strength of our culture in twelve categories of integrity

– Presents data about observed and reported misconduct

– Provides extensive benchmarking


Polling Question #3

• What is the most important element for the effectiveness of your company’s ethics program?


Agenda

• Code of Conduct Office

• Training

• Communication

• Events

• Ethics Perception Survey


Code of Conduct Program


Code of Conduct Office


• General Counsel has primary responsibility for compliance and ethics function

• Code of Conduct Program Manager handles day to day operations of the ethics function, such as: • Communications • Investigations • Training

• Reports up to the General Counsel with direct access to the board committee, audit committee, and governance committee chairs

Code of Conduct


• Available to all employees & field staff

Code of Conduct

Escalation Process

Code of Conduct

• Our Code covers:

– Putting the Code Into Practice

– Respectful Workplace

– Privacy and Information Protection

– Conflicts of Interest and Outside Business Activities

– Financial Management and Disclosure

– Compliance with Laws, Rules and Regulations


Training


New Employees & Financial Representatives

Training


Annual Recertification

• CBTs – Created internally or use a vendor

• In person

• Includes: • Hot topics

• Code of Conduct refresher

• Non-Retaliation

• Gifts & Business Entertainment

• Other hot topics for the Code of Conduct Office

Training


Leader Training & Resources

Intranet site for managers

Communication

• Communication Channels

– Blog

– Workplace News

– Leader News

– Top News Stories

– Intranet site dedicated to the Code of Conduct


Events

• Ethics Awareness Month – White-Collar

Fraudsters

– Ethics in Action Panel

– Outside ethicist speaker

– Case Studies

– Opening the black box


Ethics Perception Survey

• Included in the benchmark: – Comfort speaking up

– Organizational justice

– Direct manager leadership

– Tone at the top

– Openness of communication

– Departmental Climate

– Clarity of Expectations

• Additional Components measured: – Awareness

– Ethical pressure

– Fairness

– Transparency & Communication


Polling Question #4

• What tool do you use most often to measure the effectiveness of your ethics program?


Knights of Columbus: Keeping the Promise

• Content must be relevant, comprehensive, and concise

• Support from the Top

• Aiming for the Middle

• Easily Accessible

• Reinforced as often as possible

• Consistently Applied

• Fairly enforced


Defining Code Content

• Overall vision from the top

• Utilize resources across the Order: – Compliance

– Legal

– Human Resources

– Operational Departments

– Field Management

– Graphics/Marketing


Getting it down in writing

• Emphasis on Core Values and Principles

• Reference other Policies, don’t necessarily include them in the Code

• Update Consistently, more often if needed

• General, to be inclusive, but Specific to be meaningful

• Get as much input as reasonably possible from cross-functional areas



Core Values

Strong, visible support from the top

• CEO messaging – Introduction to the Code

– Periodic Messaging throughout

– Multiple mechanisms

• Focus on values, principles and reputation

• Global organizational results, requiring every individual’s efforts



Aiming for ‘the Middle’

• Important to get Management and Leaders support and buy-in: – Separate section within the Code

– Creation of the ‘Management Playbook’, helping in consistently applying Code

– In-person, interactive management training

– Periodic reminders through intranet/memos/meetings

• Worksheets to help document



Value Question

Integrity:

Firm adherence to ethics, honesty, and a moral code.

• Is my behavior consistent with our Core Values? • Do I comply with the Code, our policies, and all laws? • Do I regularly encourage open discussions about integrity? • Am I a good ethical role model?

Professionalism: Promoting the highest standards

in all we do.

• Do I promote an open door policy, take the time to hear employee concerns, and respond appropriately?

• Do I empower my employees to deal adequately with customer issues and concerns? • Do I provide good leadership that my employees can emulate? • Do I use company assets (including my time) responsibly and encourage others to

do so?

Excellence: Leading by example and constantly striving to be

the best.

• Do I support a healthy work/life balance for my employees and demonstrate this with my own actions?

• Do I always promote a “customer first” mentality? • Do I demonstrate a commitment to customer satisfaction and encourage my

employees to do the same? • Am I unwavering in my commitment to quality?

Respect:

Treating each other with the highest regard.

• Do I treat others with respect? • Do I hold others to the same standards I keep? • Do I find ways to recognize my employees who do the same? • Do I communicate my expectations clearly and regularly? • Do I protect my employees’ confidentiality?

Knights of Columbus Core Values: Manager Self-Assessment


Accessible on Multiple Platforms

• Hard copy – Glossy/Professional look & feel • Intranet • ‘Public version’ coming soon to internet • Overview Training through LMS • In-person interactive training • Short Video ‘vignettes’ • Posters • Wallet-size ‘Core Value’ & Help Line cards


Consistent Application & Fairness

• Code can’t cover every situation

• Cross-Functional committee evaluates reported Code violations – Committee strives for fairness/consistency

– Issues are closely monitored for trend analysis/systematic problems

– Training/corrective action flexibility to address matters


Questions / Answers


We’d love to hear from you.

For any questions or comments regarding this presentation, please contact:

Donald J. Walters President & CEO Compliance & Ethics Forum for Life Insurers (240) 744-3027 [email protected]

For more information on this webinar and other CEFLI webinars, please go to: www.cefli.org


mailto:[email protected]


Compliance & Ethics Forum for Life Insurers www.cefli.org

Ethics - cefli.org€¦ · COMPLIANCE & ETHICS FORUM FOR LIFE INSURERS Ethics Administration and Oversight of a Company's Code of Conduct or Ethics Program Educational Webinar

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