Presented By:
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Managers.
Your Toolkit to Building Effective In‐House Compliance Programs on a Budget
Megan M. Belcher, Vice President and Chief Counsel, Employment Law and Compliance, ConAgra Foods
Catherine Cook, Senior Director, AdvanceLaw
Laura Danysh, Vice President and Senior Counsel, Global Compliance and Ethics, Hilton Worldwide
Presented By:
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Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Instilling a Culture of Compliance – Megan M. Belcher
Creating a Training and Awareness Program – Laura Danysh
Monitoring Risks & Measuring Effectiveness – Catherine Cook
Road Map for Our Discussion
Presented By:
Developing a Culture of Compliance
Step 1: Teach your organization how corporate culture affects misconduct
• Understand the state of misconduct where your business operates
• Preempting compliance failures
• Assessing the impact of your corporate culture on your organization’s compliance risk
Presented By:
Developing a Culture of Compliance
Step 2: Learn and illustrate how corporate culture affects your business performance
• Show how compliance helps the business succeed
• Understand the connection between corporate culture and business performance
• Make the business case for a corporate culture
• Demonstrate the value of the compliance program to your organization
Presented By:
This chart shows how many hotel Team
Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Business Case for a Culture of Compliance
Culture of Compliance
• A strong culture of integrity correlates positively with long‐term total shareholder return.
• Employees in high integrity cultures are 67% less likely to observe significant instances of business misconduct.
• Employee productivity increases by 12% if their managers exhibit ethical values and behavior.
• Ethical companies receive widespread public attention, secure the trust of customers and suppliers, and better attract and retain talent.
Business and Financial
Performance
Employee Engagement and Productivity
Reputation and Goodwill
Risk Management and Levels of Misconduct
1 2 43
Driving process
improvement aimed at a culture of
compliance and integrity reduces risk, while also improving
employee and business
performanceSource: CEB CELC Research, “Ethical Leadership – The Important Links Between Culture, Risk Management, and Business Performance.
What is the business case for instilling a culture of compliance?
Presented By:
Instilling a Culture of Compliance
• Improve tone at the top
• Foster a sense of organizational justice
• Build integrity into business practices
• Train high integrity employees
• Improve employee culture of reporting and speaking up
• Develop managers into ethical leaders
Presented By:
This chart shows how many hotel Team
Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Training Program
Identify risks and learning objectives
Prioritize risks with resources
Identify audience for each topic
Frequency, timing and length for each topic
Communication & touch points
Creating a Training Program on a Budget
Presented By:
This chart shows how many hotel Team
Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Identify Resources within the Company
Presented By:
This chart shows how many hotel Team
Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Identify Risks & Learning Objectives
Presented By:
This chart shows how many hotel Team
Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
What can be done in house?
Who has the skill set to execute?
Prioritize Risks with Resources Careful selection
of audience is important; drives cost
Vendor selection is equally important
Identify Audience
How often is audience required to train on each topic?
How much time will it take to complete each training?
Identify Frequency & Timing
Resources, Audience & Frequency
Presented By:
This chart shows how many hotel Team
Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Topic Audience Timing Touchpoints
Code of Conduct All employees, globally Q1 Q1 Q1‐4 Ongoing TBD Q2 Q2 Q3 Q4
Mandatory eLearning & instructor‐led training Newsletter article “Tales from the Hotline” newsletter Talking points for management Hotline Posters Email blast on Manager Escalation procedure & web reporting tool Onboarding training Displays at corporate offices Intranet news feed
Antitrust & Fair Competition All Managers & above, globally Q2 Q2 Q3 Q4 Ongoing
Mandatory eLearning Supplemental training (expanded audience) Newsletter article Displays at corporate offices Onboarding training
Anti‐Corruption TBD Q3 Q1, Q3 & Q4 Q3 Q2 Q2 Q3
Ongoing Q4 Q2
Mandatory eLearning Supplemental training (expanded audience) Newsletter article Red Flags list Due diligence communications to third parties/vendors Specialized management training on anti‐corruption & being leader
of company Values Onboarding training Electronic bulletin boards Manager two minute trainings pre‐meeting
Sample Communications Plan
Presented By:
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Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Operational Meetings
Leadership Training
Onboarding Classes
Professional Development Programs
Tap into Existing Programs
Presented By:
Monitoring Risks
1/3 as a stand‐
alone compliance
effort
1/3partner with internal audit
1/3as part of enterprise
risk assessment
Source: Deloitte In Focus: 2015 Compliance Trends Survey
How does the compliance risk assessment get done?
Presented By:
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Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Monitoring
How do you measure compliance program effectiveness?
Source: Deloitte Compliance Week Survey, 2014.
Presented By:
Monitoring
of incident reporting comes from hotlines; more than 65% is reported to managers Source: “Five Tips for Measuring Compliance Success,” www.CFO.com, 2015.
Presented By:
This chart shows how many hotel Team
Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
The Big One – Third Parties
Monitoring 3rd party risks – rising to the challenge?
32%38%
42%
Require Training orCertification
Perform extensivebackground checks
Audit compliance withpolicies or regulations
Source: Deloitte Compliance Trends Survey 2015.
Presented By:
Reprioritize Agenda
Source: CEB 2014 State of the Compliance & Ethics Program Survey.
1. Enforcing Policies and Procedures
2. Compliance and Ethics Training Program
3. Monitoring Third Party Controls
4. Compliance and Ethics Risk Monitoring
5. Compliance and Ethics Risk Mitigation
1. Enforcing Policies and Procedures
2. Monitoring Third Party Controls
3. Compliance and Ethics Training Programs
4. Reviewing New Business Partners
5. Compliance and Ethics Risk Monitoring
1. Monitoring Third Party Controls (ABC)
2. Compliance and Ethics Risk Monitoring
3. Compliance and Ethics Training Programs
4. Conduct Initial Due Diligence of Third Parties
5. Compliance Risk Assessment
11. Reviewing New Business Partners 7. Compliance Risk Assessment 10. Enforcing Policies and
Procedures
2010 2012 2014
Presented By:
Take an Integrated View
Assess the impact of
training and campaigns
Conduct employee surveys
Tap resources outside the ethics and compliance
officeEmpower line managers
Communicate with Board and
C‐level executives
Presented By:
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Members certified that all applicable Team Members
completed in‐person training.
This chart shows assignments of hotel Team Members by their General
Managers.
Conclusion
Q&A Session
Thank you for joining our discussion.