Developing an Integrated Anti-Fraud, Compliance, and Ethics Program

Transcription

1 Developing an Integrated Anti-Fraud, Compliance, and Ethics Program Conducting Anti-Fraud, Compliance, and Ethics Training 2018 Association of Certified Fraud Examiners, Inc.

2 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? 2018 Association of Certified Fraud Examiners, Inc. 2 of 27

3 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 Association of Certified Fraud Examiners, Inc. 3 of 27

4 Can Ethics Be Taught? 2018 Association of Certified Fraud Examiners, Inc. 4 of 27

5 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 2018 Association of Certified Fraud Examiners, Inc. 5 of 27

6 Benefits of Effective Training 2018 Association of Certified Fraud Examiners, Inc. 6 of 27

7 Common Training Challenges Source: NAVEX Global s 2015 Ethics and Compliance Training Benchmark Report 2018 Association of Certified Fraud Examiners, Inc. 7 of 27

8 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 Association of Certified Fraud Examiners, Inc. 8 of 27

9 Select the Target Audience Organization-wide training Segmented or targeted training Executive training Middle-manager training Training for the board of directors 2018 Association of Certified Fraud Examiners, Inc. 9 of 27

10 Select the Training Methods Live, instructor-led training Workshops Prerecorded presentations Online or computerbased training Mobile learning Game-based learning Micro-learning Blended learning So what is the best option? 2018 Association of Certified Fraud Examiners, Inc. 10 of 27

11 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 Association of Certified Fraud Examiners, Inc. 11 of 27

12 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 Association of Certified Fraud Examiners, Inc. 12 of 27

13 Developing the Training Content 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, government contracting, FCPA) Association of Certified Fraud Examiners, Inc. 13 of 27

14 Developing the Training Content 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 2018 Association of Certified Fraud Examiners, Inc. 14 of 27

15 Developing the Training Content 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 2018 Association of Certified Fraud Examiners, Inc. 15 of 27

16 Administering the Training Use actual case examples. Use cascading training. Address geographical variations: Language Timing and presentation approach Cultural factors Require employees to certify attendance Association of Certified Fraud Examiners, Inc. 16 of 27

17 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) 2018 Association of Certified Fraud Examiners, Inc. 17 of 27

18 Solicit participant feedback. Assess training effectiveness. Evaluating the Training Review training records when issues arise Association of Certified Fraud Examiners, Inc. 18 of 27