2011 Ethics and Compliance Training: A Guided Tour of ELT’s Ethics and Code of Conduct Online Compliance Course
How To Provide Superior Ethics Training
Nov 29, 2014
This interactive webinar will give you a live, guided demo of ELT’s online Ethics & Code of Conduct training program, discuss the laws that mandate training, and provide a practical overview of best training practices.
Online ethics training programs have become critical to many organization’s compliance and risk management strategies. Legal mandates over the past decade have significantly reduced fines and penalties for organizations that train employees on their Code. The regulatory environment continues intensify, demanding increased accountability and transparency from employers.
More than ever, organizations have a strong incentive to build both an ethical culture and effective compliance programs – to reduce risk, to avoid litigation, to build defenses and to create tangible value. Enterprise-wide employee education is central to this effort.
Online ethics training programs have become critical to many organization’s compliance and risk management strategies. Legal mandates over the past decade have significantly reduced fines and penalties for organizations that train employees on their Code. The regulatory environment continues intensify, demanding increased accountability and transparency from employers.
More than ever, organizations have a strong incentive to build both an ethical culture and effective compliance programs – to reduce risk, to avoid litigation, to build defenses and to create tangible value. Enterprise-wide employee education is central to this effort.
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2011 Ethics and Compliance Training:
A Guided Tour of ELT’s Ethics and Code of Conduct
Online Compliance Course
Reid Bowman, Esq.
General Counsel of ELT.
Over 25 years of HR and labor & employment law experience, primarily working with multi-state employers.
Designs strategic ethics, wage & hour, discrimination prevention, and employment law compliance programs.
Scott Schneider, Esq.
Director of Compliance
Over 10 years experience representing aerospace industry in environmental and compliance matters.
Over 10 years of experience helping employers roll out organization-wide online ethics and compliance programs.
Legal Requirements for Ethics & Code of Conduct Training
Translating the legal requirements: a demonstration of ELT’s Ethics & Code of Conduct Training course
Ethics & Code of Conduct Best Practices
Agenda
A Question for You?
Which best describes your organization’s ethics training efforts:
1.Not thinking about it yet
2.In the process of reviewing options
3.We’ve selected a resource but are waiting to implement
4.Already started training
Legal Requirements for Ethics & Code of Conduct Training
Laws that Mandate Training
key drivers for training:
1. The Sarbanes-Oxley Act of 2002 (SOX).
2. The 2004 Federal Sentencing Guidelines Amendments (FSGs).
3. 2007 & 2008 amendments to the Federal Acquisition Regulations (FAR).
Code distribution is not enough.
3
The Federal Sentencing Guidelines
Rules that set out a uniform sentencing
policy for defendants.
U.S. SENTENCING GUIDELINES,§ 8B2.1 introductory Committee.
What?
Who?
How?
Why?
The Federal Sentencing Guidelines
All organizations, whether privately or publicly held
Must provide all employees and managers with effective and “periodic” ethics and legal compliance training.
– Quality matters.– Training must be ongoing.
2004 Amendments to Federal Sentencing Guidelines
What?
Who?
How?
Why?
The Federal Sentencing Guidelines
Training audience is broad
Must Train members of the governing authority, high-level personnel, substantial authority personnel, the organization's employees, and, as appropriate, the organization's agents.
Across the organization
What?
Who?
How?
Why?
The Federal Sentencing Guidelines
The Guidelines specifically reference the need to conduct
“effective training programs."
Distributing a Code of Conduct is not enough.
What?
Who?
How?
Why?
The Federal Sentencing Guidelines
“The potential fine range … can be significantly reduced – in some cases up to 95% – if an organization can demonstrate that it had put in place an effective compliance and ethics program.”
UNITED STATES SENTENCING COMM., AN OVERVIEW OF THE ORGANIZATION GUIDELINES (2004).
What?
Who?
How?
Why?
Understanding SOX
Applies to publicly traded companies.
Outlines requirements for Code disclosure.
Does not actually mandate ethics and Code of Conduct training.
Strongly encourages education.
SOX & Private Employers?
SOX standards are being widely embraced by privately held companies:
Good business practice to mitigate risk & liability.
Similar legislation expected for private companies.
Many privately held companies become public.
Apply to contracts worth $5 million or more and which require at least 120 days to perform.
Must develop a written Code of Ethics and Business Conduct within 30 days of the contract award; and
Must promote compliance within 90 days after the award by establishing an employee ethics and compliance training program.
2007 and 2008Amendments to FAR
The Federal Acquisition Regulations
The Federal Acquisition Regulations
Must train everyone – not just the people actually involved in executing the government contract.
Requirement flows through to subcontractors.
Requires broad-based Code training – not just on the regulations or how to do business with the government.
Training must be “ongoing.”
2007 and 2008Amendments to FAR
So what does this really mean?
Basically…
FSG requirements now applied to government
contractors through amendments to FAR
New Legislation: Dodd-Frank Wall Street Reform & Consumer Protection Act (2010) Contains Sweeping New Whistleblower
Protections For Employees In The Financial Services Industry.
Incentive program to encourage individuals to report Securities Exchange Act violations;
Raises burden of proof on employers in certain whistleblower claims.
Amends Sarbanes-Oxley and the False Claims Act to provide broader protection to whistleblowers.
+ Demonstration
Ethics and Code of Conduct
Effective, Impactful Interactivity
Innovative Modular Design
Designed to Deliver Your Message
Effective, Impactful Training Design
Ethics Fundamentals News Story
Digital Library
5-7 Minutes Topics on Key Compliance Topics
+
Ethical Misstep Followedfrom Beginning to End
Modular, Digital Library
5-7 minutes each
Concise, relevant lessons
Media rich interactive exercises
Modular
Digital Library of Topics
33 Modular Library Topics
1. Anti-Money Laundering2. Antitrust Basics3. Antitrust Advanced4. Asset Protection5. Code of Conduct – Definition and Importance6. Compensation & Bonuses7. Competing & Dealing Ethically8. Confidential Information9. Conflicts of Interest10. Documents & Records Protection11. Ethical Cultures & Values / Ethical Decision
Making12. Environmental Responsibility13. FCPA 14. FCPA Advanced15. Financial Integrity 16. Fraud & Misappropriation
17. Gift Giving and Receiving18. Government Contracting19. Harassment &
Discrimination 20. Health & Safety21. Information Security22. Intellectual Property23. Insider Trading24. Political Activity25. Pretexting26. Privacy27. Record Keeping28. Reporting29. Sarbanes-Oxley 30. Social Responsibility31. Third Party Management32. Technology Use33. Wage & Hour Compliance
Library of 34 Critical Compliance
Topics
FCPA
Insider Trading
Export Controls
Info Security
Reporting
Comp. & Bonuses
Reporting
Sarbanes-Oxley
Health & Safety
Harass. & Discrim.
Fin. Integrity
Gov’t Contracts
Intellect. Property
Asset Protection
Antitrust
Privacy
Record Keeping
Pretexting
3rd Party Mgmnt.
Technology Use
Designed to Deliver Your Message
Choose the topics that matter to your
organization
Map to Your Code
Designed to Deliver Your Message
Asset Protection
Antitrust
Privacy
Record Keeping
FCPA
Insider Trading
Export Controls
Info Security
Reporting
Comp. & Bonuses
Reporting
Sarbanes-Oxley
Health & Safety
Harass. & Discrim.
Fin. Integrity
Gov’t Contracts
Intellect. Property
Pretexting
3rd Party Mgmnt.
Technology Use
Your topics appear as the digital
library
You control course length
Designed to Deliver Your Message
Designed to Deliver Your Message
Tailor Topics Choice to Audience Needs
The Core Course
++
Ethics in the Workplace News Story
Digital Library with Your Topics
Questions, Code & Reporting
Introduction & Course Orientation
Conclusion, Resources Screen & Electronic Certification
Ethics and Code Best Practices
Strategies for Success
Secure high level sponsorship: HR, Legal, Employee Relations, Risk Management, IT.
Carefully manage the “buy in” process; designate a clear project owner.
Mandate the training with a top down directive.
Carefully manage the customization process – balancing the “wish list” against time, expense and viability.
Set clear goals and metrics for:
– Completion rates.– Employee feedback.– Reduced claims & liability.– Behavior change.
Strategies for Success
Implement Effective Training: Invest in a focused set of quality courses you can
really use.
Strategies for Success
If your organization may be interested in purchasing ELT’s online training solutions, and you would like an ELT Sales Executive to follow up with you…
Type "YES" in the box below.
A Question for You?
Interested in our solutions?
[email protected] │ 877.358.4621
Additional substantive questions?
[email protected]@elt-inc.com
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