Compliance Culture in Global Operations Cedric Mulfinger- Global Business Compliance Program Manager

Transcription

1 If you can read this Click on the icon to choose a picture or Reset the slide. To Reset: Right click on the slide thumbnail and select reset slide or choose the Reset button on the Home ribbon (next to the font choice box) If you can read this Click on the icon to choose a picture or Reset the slide. To Reset: Right click on the slide thumbnail and select reset slide or choose the Reset button on the Home ribbon (next to the font choice box) Compliance Culture in Global Operations Cedric Mulfinger- Global Business Compliance Program Manager Johnson Controls International, plc

2 Johnson Controls recent merger with Tyco in September Employees in 150 countries

3 Global diversified technology and multi industrial leader

4 Compliance Histories Johnson Controls FCPA Enforcement 2007; $22M Fines; 3 year Monitor; DPA FCPA Enforcement 2016; $14M Fines; 1 Year Reporting 2017 EU Cartel: No Fines due to Leniency Decentralized Compliance Program Tyco Significant Growth Through Acquisition FCPA Enforcement 2012; $26M Fines; 3 Year NPA 2008 EU Cartel: $8M fine Centralized Compliance Program

5 Compliance Program Elements Program Monitoring Ownership Metrics Auditing Ethical Leadership Speak-Up Culture Organizational Justice Measurement Commitment Governance Resources Roles/Responsibilities Remediation Process Ownership Risk Assessment Risk Awareness Risk Surveillance Risk Mitigation Third Party Risk M&A - JV Reporting Mechanism Measurement/Analysis Investigation Management Development Applicability Accessibility Maintenance Ethics Policy Content Audience Channels Assessment/Certification Tracking Content Relevance/Audience Channels Frequency Ethics and Compliance - PRIVILEGED & CONFIDENTIAL

6 Compliance Missions is Driven by our Values 2017 Global Compliance team Mission: We promote a culture of ethics and integrity that empowers our people and partners to make values-inspired choices to advance business objectives.

7 Which factors drive individual employee behavior? External Environment Corporate Standards Vision and Values Leadership Finance driven Policies & Procedures Home/Life Obligations Culture Market Partners Business practices Employee Manager Connected Trust Performance Development Recognition Shared Experiences Local experience Team

8 What can influence the cultural values? Local Reality Culture Market Partners Risks Business practices. Consistency Credibility Clarity Reinforcement at all levels Company standards Code of Ethics Tone at the Top Policies and Procedures Investigations Forensic testing

9 How to foster a Global Compliance Culture? Executive Leadership is key Company standards Bottom-up Risk Analysis Deployment Speak up Geographic Program Leaders Top-Down Monitoring Program Risk Management Governance

10 How can Compliance be part of the employment experience? Management Personal Experience Team Experience Employment Life Cycle Recruiting Onboarding Promotions Career Moments Managing Exiting Company standards Code of Ethics Leader Expectation Model Compliance Education Program Reward Successes Punish Failures Strategic Talent Review Personal Development Plans

11 Leader Expectation Model drives the right behaviors Management Company standards Personal Experience Measurement Aligned with Code of Ethics Goals and Objectives Performance Reviews Strategic talent Reviews Team Experience

12 How to create local culture of Compliance? Management Personal Experience Team Experience Manager tool kit Values in Action Personal Stories Risk Discussions Training Videos Success and Failures Company standards Ethics Helpline Speak Up Campaign Lessons Learned Investigation Insights Portal Stories Town Halls/Summits

13 Compliance Education Program Live Training Corporate and compliance-led training across all business units and regions Business-related training on key risk topics (DoA, for example) Annual Vital Values Training Code of ethics certification Assigned to all employees with and computer access Values in Action Scenario-based, manager-led discussions Assigned via LMS to all people managers New Hire Training Online training for those with and computer access Live on boarding delivered by HR w/ training on values & code of conduct

14 Compliance Education cadence Multiple opportunities to discuss Compliance within the team

15 Compliance Communications Schedule Compliance Team Meeting July 19, 2017

16 DRIVERS OF CULTURE AND BEHAVIOUR CHANGE LEADER BEHAVIOUR MANAGEMENT PROCESSES Management Personal Experience Consistency Credibility Clarity Reinforcement at all levels Company standards Code of Ethics JCI VALUES FIRST LEADER DEVELOPMENT JCI BUSINESS GOALS Team Experience ANNUAL OBJECTIVES Measurement Goals and Objectives Performance Reviews Forensic Reviews/ Audits

17 Zero Tolerance Reminder All employees must understand that while we will be aggressive in the marketplace we will not compromise our ethical standards, even if it means not getting the job. At Johnson Controls, we will not tolerate threats or retaliation against anyone who makes a good-faith report of a possible Ethics Policy violation. We will continue to have zero tolerance for ethical violations. 17 Johnson Controls International, plc - Confidential

18 Thank you Manager Forum #12 - May 13, 2016