developing an integrated anti-fraud, compliance, and ...€¦ · © 2020 association of certified...

© 2020 Association of Certified Fraud Examiners, Inc.

Developing an Integrated

Anti-Fraud, Compliance, and

Ethics Program

Conducting Anti-Fraud,

Compliance, and Ethics Training


Discussion Questions

1. Do employees in your organization receive

formal compliance and ethics training? If so,

how is it conducted? Do all employees receive

the same training, or is there any variation in

content or presentation?

2. What information do employees in your

organization get regarding fraud risks and

procedures for reporting suspected fraud? What

methods are used to disseminate this

information?


Introduction

▪ Management should use

the training program to

educate employees

about why ethics and

compliance matter—

both to the organization

as a whole and to them

as individual employees.


Can Ethics Be Taught?


Benefits of Effective Training

▪ Reinforces the organization’s:

• Commitment to ethics and compliance

• Strong anti-fraud stance

▪ Empowers employees and results in better

ethical decision-making

▪ Increases compliance and reduces violations

▪ Fosters a culture of trust and honesty

▪ Improves employee morale and increases job

satisfaction

▪ Increases the quality of tips received


Common Training Challenges

Source: NAVEX Global’s 2018 Ethics and Compliance Training Benchmark Report


Planning the Training

▪ Define the training needs.

• Assess the current knowledge base.

• Determine the ideal knowledge base.

• Use training to fill the gap between these points.

▪ Outline the learning objectives.

• They must be clear, specific, and measurable.

• They must describe what learners will be able to do

because of the training, not just what they will know.

• “Following this training, employees will be able to . . .”


Select the Target Audience

▪ Organization-wide training

▪ Segmented or targeted training

▪ Executive training

▪ Middle-manager training

▪ Training for the board of directors


Select the Training Methods

Live, instructor-led

trainingWorkshops

Prerecorded presentations

Online or computer-

based training

Mobile learning

Game-based learning

Micro-learningBlended learning

So what is the best option?


Determine the Training Frequency

▪ Frequent exposure is key.

▪ Train at the time of hire.

▪ Provide refresher training at least annually.

▪ Provide additional training when policy changes

are made.

▪ Provide additional training when issues reveal

that it is necessary.


Developing the Training Content

▪ In-house staff who have the following

qualifications should develop the training content:

• Expertise in the organization’s compliance and

ethics risks

• Experience in employee training

▪ Tailor content to the organization and the

audience.

▪ Focus on highest-risk areas.

▪ Include both compliance and values-based ethics

training.



▪ Include a discussion of

the organization’s codes

and policies that support

the compliance and

ethics program.

▪ Include sections on

specific risks (e.g.,

conflicts of interest,

bribery and corruption,

government contracting).



▪ Provide information on how and why to engage

in ethical behavior:

• The connection between compliance, ethics, and fraud

• What to do and what not to do—how to understand

and interpret the company’s codes, policies, and

ethical expectations

• How to make ethical decisions

• Where to turn for ethical guidance

• How to report suspected unethical behavior or

compliance violations



▪ Include targeted anti-fraud training:

• What fraud is and what it isn’t

• How fraud hurts the organization

• How fraud hurts employees

• Who perpetrates fraud

• How to identify fraud (common financial, transactional,

and behavioral red flags)

• How to report fraud

• The punishment for fraudulent acts


Administering the Training

▪ Use actual case examples.

▪ Implement cascading training.

▪ Address geographical variations:

• Language

• Timing and presentation approach

• Cultural factors

▪ Require employees to certify attendance.


Reinforcing the Training

▪ Provide continual exposure to compliance and

ethics messaging:

• Posters

• Newsletters and blogs

• Dedicated section on company intranet

• Responsive resource for advice (e.g., “Ask the

CECO,” or dedicated discussion forum)


Evaluating the Training

▪ Solicit participant

feedback.

▪ Assess training

effectiveness.

▪ Review training records

when issues arise.

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