Finding the Right Fit: Integrating Technology to Enhance Your Ethics and Compliance Program and Mitigate Risk

Transcription

1 Finding the Right Fit: to Enhance Your Ethics and Compliance Program and Mitigate Risk SCCE Compliance and Ethics Institute Chicago, IL September 17, 2014 Who We Are: Caroline McMichen, CECO Favorite beer = Blue Moon with an orange Experience in both E&C and Internal Audit Technology challenged Jennifer Oriel, Global Manager, Training and Communications Midwesterner at heart (go WI Badgers!) Came up through the HR ranks 1

2 We support over 10,000 employees and 12 languages in 15+ countries Central Europe Bulgaria Czech Croatia Hungary Montenegro Romania Serbia Canada Russia United Kingdom Ukraine China Denver Mexico Japan Spain Miami Hong Kong Caribbean/C. America India 3 Extraordinary Brands to Delight the World s Beer Drinkers 4 2

3 Finding the Right Fit In this workshop, we will discuss: Challenges and opportunities for using technology to enhance ethics and compliance programs and mitigate risk in global organizational settings. Our journey to leverage technology: real world examples of online solutions designed to engage a global audience, enable meaningful ethics and compliance, and mitigate risk. Assess your challenges and potential technology solutions. Finding the Right Fit Agenda 8:00-8:45 am: Presentation 8:45-9:00 am: Q&As and short break 9:00-9:45 am: Facilitated table exercise 3

4 The Case for Most of the Greatest Barriers to Achieving Program Success* can be reduced through the leveraging of technology. * From CELC 2012 State of the Function survey Trends In 2012, E&C departments spent roughly half on technology what they spend on training and communications. * From CELC 2012 State of the Function surveys 4

5 Trends Technology has historically been used in the areas of risk assessment, training, investigations, and policy management whether purchased or created internally. * From CELC 2012 State of the Function survey Trends GRC solutions - The holy grail for E&C? Document compliance controls and activities Track completion of training, due diligence and other compliance activities Report results of activities to stakeholders Assign owners to risk mitigation plans and track progress Analyze trends and surface / assess risk areas Provide avenues for disclosure and recording of COI and/or G&E Manage policy development, maintenance and communication 5

6 Trends From the CELC 2014 State of the Function Survey: 23% of compliance teams reported they currently use a GRC vendor 11% are considering employing a GRC vendor For companies without a GRC system, 87% use an in-house developed monitoring tool/system BUT, 47% of those using a GRC vendor reported spending $300,000 or more to purchase and/or implement the system. Enhance Your Program and Mitigate Risk Technology can enhance effectiveness of many program elements: Written Standards Interactive Code of Conduct Policy Management tools Training & Communication Learning Management Systems Communication Portals Social Media Auditing & Monitoring Risk Assessment Due Diligence Disclosure tools (COI, G&E) Predictive Monitoring Helpline / Case Management Surveys 6

7 Many E&C teams, including ours, face: Challenges & Opportunities Rapid business growth through M&A Higher risk profile due to growth in emerging markets More complex employee base, i.e. culture, language Decentralized IT systems IT infrastructure doesn t keep pace with business growth Employees without online access Competing business priorities Integration efforts slower than ideal E&C (and other) resource constraints No history of compliance challenges Where to Start: Building a Business Case Building a Business Case Pre-work: Program Assessment Step 1: Identify and Prioritize your risk areas and program gaps Where are there opportunities for improvement in program design or effectiveness? Are there areas where great effort doesn t yield great result? Where are there existing pain points? 7

8 Building a Business Case Step 2: Define your goal to mitigate risk, to improve a process, to communicate better? Technology is not a solution, it is an enabler. (CEB analysis) Take the time to understand and document problems and processes before considering your technology options or vendors. REALLY understand your needs and objectives: Do you need the Cadillac or a Subaru? Look for a solution that is fit for purpose rather than buy in to all the bells and whistles available. It will be a bad investment in a solution that doesn t meet you needs. Building a Business Case Step 3: Get stakeholder Input and thus, Buy-In Technology investments fail when leadership fails to uncover and articulate true user needs and neglects to include the user in solution design and rollout. (CEB Legal Realizing Technology s Productivity Promise.) Clearly defined business need Executive support Enterprise mindset - How else might it be leveraged by the business? End-user input 8

9 Building a Business Case Step 4: Scope your effort Does it really belong in E&C? Ownership? Do you have the budget? Make or buy? What resources will be needed? What can IT support? Does it fit into overall architecture? How will it partner with other, existing systems (HR, Finance, T&E systems, etc.) Is there business partner support? Realistically, how long will it take to implement? Building a Business Case Step 5: How will you determine success? Effective rollout support and communication is critical User experience dictates technology performance (CEB analysis of 51 system rollouts) Step 6: Keep an eye on the future Have we established governance to maintain the integrity of the system? Do we have flexibility to change with the business if necessary? 9

10 One Example Our program assessment identified areas of opportunity to make our program more available to our employees (specifically middle managers) and more effective. Our Challenge - How Can we Better Capture an Employee s Attention and give them the tools they need? Our Solution - Create a home for E&C that pulls everything together 19 Compliance to Culture Strategies to Improve Create a home for E&C that pulls everything together 20 10

11 Our Company s Approach Understanding Our Needs and Objectives Program Assessment / Risk Assessment Employee Focus Groups Our Goal: To Create a One-Stop Shop of E&C Information and Resources Selecting the Right Partner Creativity Cost Approach to Design 21 Our Company s Approach Further Refining our Vision in a 3 Day Workshop Links to Our Brew E&C Branding, Personalization Use of Humor Does this look like a bribe to you? 22 11

12 Our Company s Approach Further Refining our Vision in a 3 Day Workshop Understanding Employee Needs 23 Our Company s Approach Further Refining our Vision in a 3 Day Workshop Understanding Practitioner s Needs 24 12

13 Our Company s Approach Getting Stakeholder Buy-In Design Implementation Plan Resources Building the Content Multiple Compliance Topic Areas Multiple Languages Keeping an Eye on the Future What Else Might Make Sense in the Space?

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15 Our Company s Approach Launching to Employees with a Communication Plan tied to Our Beer Print Month (Corporate Responsibility) Main Intranet Portal Stories and Activities Leadership and Team Member Features E&C Poll Questions, Yammer posts, local CCTV and other vehicles Everything Driving Employees to New Site If it doesn t look right, it probably isn t. 29 Our Company s Approach Measuring Success Readership for Speaking Up portal story was above average for the month of September with over 400 readers Ethics and Compliance portal launch a success receiving over 700 hits during the week Increased number of questions to key contacts listed on E&C site from employees wanting further information on compliance related topics Positive feedback from Global Leadership Team and Board of Directors Other functional areas wanting help to create a similar site 2014 Program Re-Assessment showed significant improvement 30 15

16 Our Company s Approach Ongoing Challenges Keeping Awareness High Keeping Content Fresh with Limited Resources Expanding for Acquisitions Translations 31 Other Examples Implementing new Learning Management System: Significant technical challenges with legacy LMS Needed ability to scale delivery, legacy LMS charging on a peremployee basis Gained support of business to purchase our own LMS dedicated to compliance training Significant RFP process Implementation lengthy and challenging Ongoing administration a challenge 16

17 Other Examples Online Gift & Entertainment Register Primarily used to record gifts & entertainment transparently in compliance with G&E and Anti-corruption policies Also used to monitor potential conflicts of interest, i.e. supplier relationships Provides another way to measure value for spend 33 Our Company s Approach 34 17

18 Other Examples Integrating Social Media as an E&C tool Using blogs / posts to engage employees Monitor culture without squelching the conversation 18

19 Success? Significant Improvement in 2014 Program Assessment Results Overall score raised a grade level Every measure (culture, employee knowledge, compliance environment) showed improvement from prior assessment So.even if you are not ready for the holy grail (GRC), incremental use of technology to enhance your program is well worth it! Q&A and short break will be followed by a facilitated table exercise 19

20 Exercise: Each table will be given an improvement opportunity (with related businesses challenges) for their program and be asked to brainstorm potential technology solutions build a business case and implementation plan for their chosen solution using tools provided 20