The Compliance Data #CW18

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1 The Compliance Data Machine

2 Speakers Christopher Annand Director, Global Ethics & Compliance Cargill Susan Castaneda AVP and Compliance Officer The Hartford Ilona Niemi VP, Chief Compliance Officer Zurich Insurance Company Moderator: Neha Gupta Chief Executive Officer True Office Learning

3 Cargill Overview We are: Privately-held, global corporation based in Wayzata, Minnesota Our Business Segments: Food Agriculture Financial Industrial Our Purpose To be the leader in nourishing the world in a safe, responsible and sustainable way

4 Christopher Annand Director Global Ethics & Compliance Office Leader of international team positioned against centralized compliance operations. Responsible for Code of Conduct, global mandatory compliance curriculum, policy administration and outreach programs. Joined Cargill in 2013, previously served as Compliance Director with Ameriprise Financial. 15+ years of compliance experience, supplemented by earlier marketing / communications roles. Currently working on digital code and enhanced metrics / reporting systems.

5 The Hartford Overview We are: Fortune 500 insurance group, sold primarily through independent agents/brokers Our Business Segments: Property Insurance Casualty Insurance Group Benefits Mutual Funds Our Purpose To help customers prepare for the unexpected and protect what s important to them

6 Susan Castaneda Compliance Officer Enterprise Compliance Programs Over 25 years of experience in the insurance industry serving in a number of operational, sales, underwriting, and compliance leadership roles. Leads a team responsible for corporate compliance functions, including compliance standards & programs, compliance data & analytics, regulatory affairs, ethics office, and training & awareness. Also the compliance officer for the Enterprise Data Organization, the Corporate Technology Officer and Strategic Sourcing & Real-Estate. Castaneda is a licensed property & casualty agent and serves as the signatory for The Hartford s Property & Casualty business. Before joining the law department, Castaneda held a number of leadership roles at The Hartford.

7 @ComplianceWeek #CW2018

8 Ilona Niemi VP, Compliance Officer Zurich Canada Responsible for Zurich Canada's compliance program including promoting an ethics-based culture, delivering practical compliance solutions, and providing assurance that compliance risks are identified and managed. Prior to transferring to Zurich Canada, Ilona held the role of Head of Global Compliance Oversight and Reporting in the Corporate Office of Zurich Insurance Company in Switzerland. She was responsible for managing global compliance reporting and oversight outcomes across five regions. She joined Zurich Insurance Company in 2008 serving as Head of Corporate Center Public Policy Issues. In this role she managed Zurich s International Advisory Council, a group of business leaders, former heads of state, ministers and academics from mature and emerging markets, which advised Zurich s CEO and senior executives on market entry and access strategies. From 2006 to 2008 Ilona worked as consultant for IFOK communications and strategy consulting in Germany and Washington D.C. Preceding that, she served two years as EU policy advisor representing RLP in Brussels. Ilona started her career at TCW Management Consulting in Munich.

9 True Office Learning We are: Creators of groundbreaking adaptive learning and analytics platform for the enterprise 4.1+ Million 43 Million USERS TRAINED BY DOING D ATA P O I N T S A N A LY Z E D Our Business Segments: Scholar Learning Solutions Scholar Diagnostic Solutions Poet Authoring Solutions 20 Million I.Q. Analytics Solutions H O U R S S AV E D O N T R A I N I N G 3 Million S TA N D A R D I Z E D D ATA S E T S FOR BENCHMARKING Our Purpose To help employees and organizations become better at what they do 1, C L I E N T S G L O B A L LY COURSES & MODULES REALBIZ SHORTS

10 Neha Gupta Chief Executive Officer, True Office Learning Responsible for True Office Learning s product and technology vision, strategy and growth. Previously, Senior Director of Learning Solutions & Strategic Initiatives at NYSE Governance Services, leading all product strategy and development initiatives for the business. Served as Citigroup s Chief of Staff for the Institutional Clients Group Technology organization, reporting directly to the CIO. In her time with Citigroup, Neha led a number of strategic change management efforts involving critical, multi-million dollar initiatives across industries. Neha holds an MBA in Management and Business Strategy and has been featured on many media outlets, including BBC.

11 MEANINGFUL METRICS Driving Organizational #CW2018

12 How many: Use one or two metrics to measure their compliance program and organization s risk profile? Use two or more data sources to measure their compliance program and organization s risk profile? Audience #CW2018

13 Incident/Hotline Reporting # of valid cases vs. unfounded % Incidents reported based on tiers: Region/countries Areas of business Levels of individuals reporting Benchmark internally and externally Compare to Behavioral Performance trends

14 Behavioral Analytics Going beyond training completion metrics (% complete and on-time completion) Training is an untapped source of behavior intelligence: Risk Area XYZ Company Behavioral Performance Behavioral Performance 75% Controlled Items, Licenses and Permits 80% Sanctioned and Restricted Parties 90% Overall Payments Introduction 86% 87% 79% Abuse of Market Power 69% Overall Reporting Violations 94% 89% 80% Anticompetitive Agreements 83% Performing Due Diligence 89% Export Controls (207 learners) Overall Export Basics 86% Anti-Corruption (1,148 learners) Competition and Antitrust Global (4,641 learners) Economic Sanctions (1,004 learners) Overall Roles and Reporting Business Partners 91% 95% Third Parties Expenses Recordkeeping 84% Communication and Documentation 89% Introduction to Economic Sanctions 96% 87% Reporting and NonRetaliation 93% Types of Sanctions Programs 100% 92% Competition and Antitrust Laws 100% Questions and Concerns 94%

15 Behavioral Segmentation & Benchmarking Focus on behavior trends across the portfolio Deep dive through segmentation and benchmarking

16 Risk Assessment Results Understanding top risks, their impact and maturity rating/control rating Insider Trading Competition and Antitrust Harassment Information Security Anti Corruption Diversity and Inclusion Ethical Decision Making Conflicts of Interest Anti Money Laundering Economic Sanctions

17 Sentiment Metrics Voice of Employee / Culture Surveys eliminating response bias Ethical Confidence Questions sentiment vs. performance

18 Audience Poll What other metrics do you #CW2018

19 THE COMPLIANCE SCORECARD Insight vs. #CW2018

20 The Compliance Scorecard Bring together all the metrics to have a comprehensive organizational view and easier comparative analysis

21 Behavioral Analytics vs. Reporting If behavioral trends show limited proficiency on a topic, incident reporting trends should be higher for that topic High Impact, High Risks areas are of higher significance Performance vs. Reporting 96 Competition and Antitrust Anti-corruption Economic Sanctions Export Controls Export Controls (207 learners) Anti-Corruption 2017 (1,148 learners) Behavioral Performance Competition and Antitrust Global (4,641 learners) Economic Sanctions (1,004 learners) Incident/Hotline Reporting

22 Sentiment vs. Performance Understanding response bias sentiment does not always translate into performance Comparative analysis helps understand the root-cause % of employees who are unable to perform appropriately as seen through behavioral analytics: Scenario 1: Socializing with clients and prospects Row Labels Highly confident Moderately confident Not confident Grand Total Scenario 2: Buying public stock of a competitor Row Labels Highly confident Moderately confident Not confident Grand Total Scenario 3: Interacting with Vendors Row Labels Highly confident Moderately confident Not confident Grand Total Count of User ID 16% 12% 20% 15% Count of User ID 18% 17% 28% 18% Count of User ID 15% 15% 13% 15%

23 Policy Management Provides a deeper dive within a single program area Allows viewer to analyze corporatelevel data or select specific business segment Cargill pays particular attention to regional and country-level data Key consideration: delivery method to audience

24 Other Benefits Resource allocation: use data to decide where to invest efforts Program planning: personalize program year over year to your audience Cost savings: reduce seat time and organizational investment Quantitative protection: behavioral analytics help prove sufficiency and efficacy Reputational evolution: more deeply integrated to business outcomes

25 Audience Poll Do you have a data analytics partner or resource you can #CW2018

26 GETTING STARTED Building the Compliance Data #CW2018

27 FEEDBACK We want to hear from you, please rate this session in the conference #CW2018

28 #CW2018

29 Sample Dashboards Multiple Areas Provides a broader view across multiple program components Allows viewer to analyze corporate-level data or select specific business segment In this example, data from risk assessment, training, hotline reporting and incident cases are grouped for analysis Key consideration: what data holds most value to consumer