Ethics and Compliance Program Implementation An Overview.
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Ethics and Compliance Program Implementation An Overview
2 Approach to Ethics/Compliance Awareness and Training Must Be Programmatic Lay Proper Groundwork Understand Technical, Cultural, Geographic and Other Issues Obtain Buy In and Support Send Clear Message Regarding Requirements Continue to Manage and Refine Program After Rollout
3 Establishing Your Program Set Up the Program for Success Define Program Goals Analyze Cultural, Geographical and Technical Issues that Affect Rollout Establish Implementation and Program Management Plan Coordinate Involvement of Appropriate Company Representatives Define Curricula for Employees Manage Weekly Status Meetings and To Do Lists to Keep Rollout on Track
4 Ongoing Plan Management Ensure Continuing Program Success Evaluate Usage Data Analyze Program Success and Failures to Refine Program Management Plan Attend Management Meetings, Seminars, “ Open Houses ” and Other Events to Market Program Provide Ongoing Plan Management (site changes, new enhancements, training, etc.)
5 Typical Implementation Steps Develop Program Management Plan Define Program Goals Identify Key Players Make Key Decisions Customize Site Incorporate Company Look and Feel Identify Tracking/Reporting Levels Design Completion Message(s) and Certificate Prepare Rollout Plan and Marketing Campaign Develop Rollout Strategy Identify Marketing Media Customize Site Marketing Materials Execute Rollout Campaign Meet with Management Advertise Site Hold Employee Open Houses Manage Program Review Site Usage Follow Through On Mandatory Requirements Continue to Advertise Program
6 Key Program Decisions Overall Plan Issues Who will be on your “Steering Committee” to manage the rollout and plan after rollout? Module selection; Which modules will be mandatory and for whom? What are the company’s goals for the program (percentage of employee base, modules completed, time frame, divisions, etc.)? Are there any impediments to employees taking modules that need to be addressed (lack of computers, disabilities, language, etc.)?
7 Key Program Decisions Customization Issues What employee data should be bulk loaded in order to manage the program and provide meaningful reporting? Will modules be pre-assigned through bulk load or will site curriculum generator be used, or both? What level of tracking and reporting will be selected? Will bulletins be written in any modules? If so, who will write them?
8 Key Program Decisions Rollout Issues What is the tone of the message you want to send as you advertise the program? What communication methods will best reach your user base? Will the rollout be done in phases or all employees at one time? What is the best way to communicate the program to management in order to obtain their buy in and support. From whom will the message to employees come?
9 Mandatory Requirement Issues Will mandatory requirements be imposed? If so, are people willing to carry them out? Which courses will be mandatory? For whom will those courses be mandatory? During what time frame must the courses be taken? What are the consequences of not taking courses? oeffect on raises, bonuses, evaluations, promotions olimitation on activities
10 Mandatory Requirement Issues Who will manage the mandatory requirements? human resources legal/compliance individual managers Will managers be evaluated based on the compliance of their direct reports?
11 Mandatory Requirement Issues How will the mandatory message be relayed to employees? How will the mandatory requirements be imposed on new employees part of orientation process completion required in order to receive e-mail address, network logon, company events, other privileges?
12 “Best Practices” for Program Management Hold weekly meetings/calls to keep rollout plan on track Roll out custom Code of Conduct with program Centralized decision-making facilitates introduction of compliance initiatives Utilizing representatives of several departments (HR, Communications, IT, EH&S) facilitates development of a successful rollout and management plan
13 “Best Practices” for Program Management Gaining acceptance of initiatives from managers across company facilitates acceptance of program by all employees Making managers responsible for the compliance of their reports helps ensure program success Mandatory requirements help set tone for strong compliance initiative and improve employee participation Following through on mandatory requirements ensures success
14 “Best Practices” for Program Management Use of “carrot” in addition to “stick” help make ethical and compliance awareness part of company culture. Conducting “open houses” at key locations to introduce site improves acceptance and utilization by all employees On-going plan management and marketing are key to a successful program