1. Ethics and Compliance Program Implementation An Overview

2. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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