Aligning Ethics Communication & Training With Business Priorities and Compliance Risks Willow Misty Parks Graduate Assistant Anderson School of Management University of New Mexico Albuquerque, NM

Why Align Your Ethics & Compliance Training and Awareness with Business Priorities –Protect your company against the risks that could have the greatest impact on your business success –These business priorities (and risks) will change over time and your ethics & compliance training and communications should adapt –Mitigates overall risk by prioritizing resources to largest and most relevant risks –Can help to improve senior business leader sponsorship and support –Drives more effective and focused training that employees can readily relate to –Helps improve employee interest and knowledge retention –Enables ability to further increase awareness through E&C awareness “campaigns” throughout year consistent with business initiatives Why Align?

Ethics & Compliance Awareness Approach: Key Points for Content and Timing Topic identification and prioritization based on business need and risk Development of topical campaigns, combining: –Required training – Awareness Development of annual calendar Tracking Content & Timing

Minimum threshold for a mandatory curriculum Topics Must: –Be aimed at a widespread, relevant audience, and – Reinforce a legal, compliance or ethical behavior Emphasize policies or Code of Business Ethics and/or Protect company from non-compliant illegal activity Threshold For Topics

Look at Changes: –New policies –Incidents –Development changes Identify what is important to the company –Determine whether to train or campaign information? –Data driven –Consistent and Flexible Identifying & Selecting Topics

Prioritization Factors Leadership drive Subject matter experts (SMEs) to identify potential exposures, understand any recent changes in the regulatory environment and emerging risk, identify incidents and the legal requirement or desirability to train Trending input from corporate investigations, human resources, litigation, global compliance monitoring and other relevant teams who can provide data and insights Aging data from E&C organization and SMEs How to Align Topics & Needs

A consistent, but flexible, year-on-year approach that can be applied across initiatives. Using comprehensive data to target the highest priorities and risks to the business. Can identify additional compliance topics for training and awareness consideration. Training and reinforcing communications focused on business priorities. Benefits of This Approach

Once we apply the prioritization factors, we do a little math Once scored, we prioritize each topic to determine which require increased awareness, and those for which we only need to maintain awareness. Create an Ethics and Compliance Curriculum Plan Steps of Approach

Develop “Topical Campaigns” Set in an annual calendar Reinforce knowledge Interest related Multiple years Tracking knowledge capture Training Schedule: Surround Sound

After Determining Training Schedule, Develop Communications Strategy: Call it a Surround Sound Approach –Holistic approach tied to prioritization –Individual communications plans for training topics –Working across initiatives – surround sound approach – all reflecting key message Training Schedule: Surround Sound

Tracking results help with continuous improvement and establish priorities for upcoming year. Best practices for increasing knowledge and awareness: consequence (e.g., performance management) Assess understanding and learning increases: - Use of pre-tests - Analysis of questions to ethics mailbox and review of reported allegations Correlate training and awareness efforts with employee activities – e.g., Visits to Code of Business Ethics site / individual web pages –Visits to specifically relevant policies and compliance portals, etc. Conduct ethical perception surveys Track Results