Effective Compliance training. Vincent Denonville

Transcription

1 Effective Compliance training Vincent Denonville 15 November 2017

2 FIFA Compliance team Chief Compliance Officer joined October 2016 Compliance staff tripled in 1 year (from 3 to 9) 1 more scheduled for 2017 Experienced Compliance team built with extensive experience and high ethical standards o o o Previous Compliance experience (Compliance experience from other regulated markets like banking industry and pharmaceutical industry) All 4 FIFA languages covered: English, German, French, Spanish Broad scale of previous work experience in the team: Effective Compliance Training 2

3 FIFA Compliance Aspiration FIFA aspires to become a leader in ethics and compliance in international sports. FIFA will work tirelessly to create a bestin-class organisation on transparency and accountability. Effective Compliance Training 3

4 Effective Compliance Training Effective Compliance Training

5 U.S. Federal Sentencing Guidelines Effective Compliance Training 5

6 Effective? Issues as indicator Frequency of training Pro-active? Level of your Compliance program / ressources available 1st FIFA Compliance Summit 2017

7 Compliance program Effective Compliance Training

8 Management Key elements Remediation Escalation Leadership communication Local communication Organization Resource allocation Risk assessment process Third party assessment adequate structure and resources tone from the top and middle management Communicate the importance of Ethics & Compliance Risk-based content Implementation and tracking Policies Procedures Effective Compliance Training 8

9 Risk based approach Effective Compliance Training 9

10 Risk Assessment Engine to Enable Leadership communication Local communication Organization Resource allocation 1. Resource allocation 2. Development of Policies & Procedures 3. Topic specific training to FIFA Staff 4. Monitoring & Testing 5. Management Reporting on Progress Remediation Escalation Risk-based content Implementation and tracking Policies Procedures Risk assessment process Third party assessment Key Elements 1. Key FIFA Risk Activities 2. Inherent Risk 3. Mitigating Controls 4. Residual Risk 5. Actions Plan Effective Compliance Training 10

11 Policies & Procedures Remediation Escalation Leadership communication Local communication Risk-based content Implementation and tracking Organization Resource allocation Policies Procedures Risk assessment process Third party assessment Key elements transparent, accessible, and understandable policies and procedures across FIFA Main policies Code of Conduct Code Ethics Anti Bribery and Corruption Gifts and Entertainment policy Conflict of Interest policy Donations Directive Effective Compliance Training 11

12 Code of Conduct Effective Compliance Training 12

13 How to define the key values? Effective Compliance Training 13

14 Tools used Cross division discussions surveys workshops Effective Compliance Training 14

15 Challenges to bring the message of the Code Engage Language Easy and convenient Complexity Transparent Effective Compliance Training 15

16 Effective Compliance Training 16

17 An example Effective Compliance Training 17

18 Compliance Induction example What is fraud? Deliberate Deception to gain an unlawful advantage A neurologist known as the father of psychoanalysis Effective Compliance Training 18

19 Freud vs. fraud Effective Compliance Training 19

20 Training Remediation Escalation Leadership communication Local communication Organization Resource allocation Risk assessment process Third party assessment Key elements consistent and effective training, identifying audiences using a targeted, risk-based approach training needs training plan evaluate training effectiveness and modify content based on emerging risks Risk-based content Implementation and tracking Policies Procedures Effective Compliance Training 20

21 Conflict of interest Effective Compliance Training 21

22 Monitoring & Testing Remediation Escalation Leadership communication Local communication Risk-based content Implementation and tracking Organization Resource allocation Policies Procedures Risk assessment process Third party assessment Key elements robust controls to ensure Compliance can enforce and monitor policies and procedures appropriate and timely mitigation systems to monitor and report on the effectiveness of the Compliance program manage and audit third party and other relationships Effective Compliance Training 22

23 Reporting/Communication Remediation Escalation Leadership communication Local communication Risk-based content Implementation and tracking Organization Resource allocation Policies Procedures Risk assessment process Third party assessment Key elements culture of compliance through clear and consistent messaging Assess communication needs communication plan Tailor communication content and delivery Centrally track, report, and archive Effective Compliance Training 23

24 In practice Effective Compliance Training

25 Effectivenes Dictionary The degree to which something is successful in producing a desired result; success. the effectiveness of the treatment Desired result of a Compliance training? Awareness of staff Know where to find in case of issues In depth application in practice what to do Expertise Effective Compliance Training 25

26 Bloom s taxonomy training tailored to the required level Effective Compliance Training 26

27 Principles K.I.S.S. Keep It Sweet Simple Effective Compliance Training 27

28 The Why from Simon Sinek Effective Compliance Training 28

29 FIFA Activity Prohibited Activities Transaction Risk Impact CONTRACTING EXPORTING SERVICES PAYMENTS Enter into re-current business relationship w ith sanctioned person Enter in One-Off business relationship w ith sanctioned person Exports to sanctioned countries Services offered to sanctioned person attending FIFA events (Provide hospitality, gifts or entertainment) Payments sent directly to sanctioned person Payments sent indirectly to a sanctioned person Author: Likelyhood & Impact? What is the difference between Impact and Compliance Risk? Direct sponsorship negotiated with sanctioned person (including arranging hospitality or tickets for sanctioned individual directly) Indirect sponsorship negotiated with sanctioned person (including arranging hospitality or tickets for sanction individual through an intermediary) Compliance Risk Impact Compliance Risk Impact Compliance Risk Impact Compliance Risk Impact Compliance Risk Impact Compliance Risk Impact Compliance Risk TV rights/ franchise licensing negotiated with sanctioned person Contracting with a sanctioned service provider contracted for tournaments (e.g. catering/ security, event management) Procurement contract with a supplier or service provider (incl. freelancers, referees, and consultants) or an employee who is a sanctioned person Providing/selling tickets or hospitality directly to a sanctioned person Providing/selling tickets or hospitality indirectly to sanctioned person One-off procurement from a supplier or service provider (incl. freelancers, referees and consultants) who is a sanctioned person. Shipments of equipment or other items to countries subject to export and/or sanctions controls Host a sanctioned person at a FIFA event (Congress, tournaments and other FIFA events) Offer a gift or entertainment to a sanctioned individual Book travel tickets for a sanctioned individual Hospitality service provided to a sanctioned person TMS - Transfer services offered to sanctioned players / clubs Payment to a sanctioned party (e.g. committee members, referees, teams, suppliers, contractors and consultants) Payment to a Member Association used by the Member Association to pay a sanctioned party Marketing Services Commercial Finance HR & Services Legal & Integrity Author: Meaning of the various colors? Controlling & Strategy Travel & Accommodation TV Services Marketing Sales Meaning & Strategy of the numbering? Accounting Consolidation & Tax Human Resources Facility Management ICT Procurement Football Regulatory Operational Legal Planning Services Impact Compliance Risk Impact Compliance Risk Impact Compliance Risk Impact Compliance Risk Impact Compliance Risk Impact Compliance Risk Integrity & Institutional Legal Impact Compliance Risk Advanced segmentation Administration Sanctions - Risk Matrix Risk exposure Departments Industry, business units Location, region, facility Languages New hires, promotions Interactions with customers, government officials, third parties, media, etc. Leading to tailor made training Effective Compliance Training 29

30 Measuring Effectiveness & New technology? From Snapshot printscreen To o o o o o Audio recording Voice recognition Virtual reality - Cockpit simulator Voice recognition Big data Gamification Effective Compliance Training 30

31 Reflections Train the trainer Compliance satellites Role of the Line Manager Campaign using different channels Poster Policy Training on the job E learning Video Examples real cases Monthly update letter Effective Compliance Training 31

32 Reflections Communication Human capacity to remember Repeat repeat repeat Combine efforts with other components Risk Assessment & Training needs identification Assessment Testing Curent Next Year Policy Training Policies & Training (1 location where to find everything) Monitoring and Testing & Training Policy Guidelines Training Material ABC Monitoring & Testing Framework Curent Suggestions Procedure in place Training given Frequency of training Audience selection undertaken Effectiveness Effective Compliance Training 32

33 Summary Risk based approach Tailor made KISS / Why Effective Compliance Training 33

34 Questions Effective Compliance Training 34

35 Effective Compliance Training 35