The Path to Compliance and Ethics Program Maturity

Transcription

1 The Path to Compliance and Ethics Program Maturity CEB Ignition Diagnostic for Compliance & Ethics Assessing the Importance and Maturity of Activities That Support Seven Compliance and Ethics Program Objectives: Define the Program Mandate Mitigate and Monitor Risks Establish Policies and Procedures Oversee Allegations of Misconduct Provide Training and Communications Reinforce Behavioral Expectations Manage the Function

2 Prioritize performance improvements that deliver the largest returns. The pace and diversity of corporate change is increasing, making and ethics more important than ever to corporate success. As a result, 74% of programs expect business demand for their services to increase in the next 24 months. At the same time, cost pressures on Compliance are growing. In fact, more than two-thirds of executives expect their budgets to remain flat or decrease in the next two years, lagging behind the expected pace of economic growth. It s hard to do more with less, especially without a clear action plan to help Compliance identify and execute on the trade-offs it must make to best support program goals. Misallocation of Compliance Staff Time Program Element Time Allocation and Priority Score Time Allocation 40% 20% 0% Training and Communications Time Allocation Compliance Risk Management 3.79 Standards and Procedures Priority Score 3.35 Allegations, Reporting, and Investigations % 31% 10% 15% 7% Program Measurement, Monitoring, and Surveillance n = 87 companies (time allocation); 260 (priority score). Source: State of the Function Survey and Program Assessment Tool offered by CEB, now Gartner. 6 High Priority 3 Priority Score 0 Low Priority 2

3 How We Can Help Prioritize areas for improvement, and develop an action plan. Diagnostic Overview Our CEB Ignition Diagnostic for Compliance & Ethics measures performance across seven objectives and 30 discrete activities. Use it to: Understand critical maturity gaps; Prioritize areas for improvement; and Create action plans to reach desired maturity. How We Measure Maturity We apply our unique, direct insight on companies strategies, tactics, and actions to ground our maturity measurements in actual practice. This evidence-based approach enables us to provide prescriptive guidance to help you reach the next level of maturity and create an actionable vision for maturity progression. Participation Details Participants: The seniormost and ethics officer, with the option to include members of the and ethics team Time Commitment: minutes Sample Report Excerpt Path to Maturity Develop a Compliance and Ethics Training Curriculum, Excerpt 1 2 Provide training as need arises. Source: CEB, now Gartner analysis. 3 Provide annual code of conduct and mandated training to all employees. 4 Cover regulatory risks aligned to industry benchmarking and an informal risk assessment. Maintain a documented annual and ethics training plan. 5 Map training to the company s risk profile. Maintain a documented multiyear and ethics training plan. Clear Steps to Improve the Maturity of Priority Areas Map training to individual employees risk profile. Manage a rolling curriculum plan to reflect internal partner feedback on need and efficacy. Include flexibility in training curriculum plan to respond to organizational change. Currently Practiced Activity Commence Activity to Achieve Next of Maturity Potential Future Activity 3

4 Our Compliance and Ethics Function Activity Map The map below represents the scope of activities for the typical and ethics program. See page 5 for more details. Manage Compliance and Ethics Risks Improve Employee Decision Making Lead the Function Define Program Mandate Mitigate and Monitor Risks Establish Policies and Procedures Oversee Allegations of Misconduct Provide Training and Communications Reinforce Behavioral Expectations Manage the Function Assess Legal and Compliance Risk Determine Program Scope and Objective Set Functional Strategy Maintain Organizational Support Track the Legal and Regulatory Environment Monitor Compliance Risk Exposure Test and Audit Compliance Build Risk-Specific Mitigation Plans Manage Third-Party Risk Maintain the Code of Conduct Maintain Policy Governance Design Policies and Procedures Embed Policies and Procedures into Operations Maintain Reporting Channels Intake and Triage Employee Reports Conduct Internal Investigations Develop a Compliance and Ethics Training Curriculum Determine Training Content Deliver Compliance and Ethics Training Measure Training Effectiveness Develop Communications Content Measure Corporate Culture Promote a Culture of Integrity Establish Incentives and Disciplinary Measures Select and Manage Service Providers Manage Talent Manage the Budget Partner with Key Stakeholders Measure and Report Program Effectiveness Deliver Compliance Messages Source: CEB, now Gartner analysis. 4

5 Path to Maturity Guide Maintain Reporting Channels Excerpt Oversee Allegations of Misconduct Maintain reporting channels. Intake and triage employee reports. Conduct internal investigations. Maturity Compliance follows up with employees who have reported to solicit feedback about the experience and implements and advertises formal anti-retaliation controls. Reporting channels are available to employees, customers, and third parties, and Compliance promotes reporting success stories to encourage reporting. Compliance ensures the various employee reporting channels are accessible by all business units and geographies and promotes their use by addressing employee concerns about reporting. 2 Compliance creates multiple avenues for employee reporting (e.g., hotline, web form, inbox) and actively promotes awareness of the reporting channels. Source: CEB, now Gartner analysis. 1 Compliance maintains one reporting channel in the form of an anonymous hotline with limited advertisement. 5

6 About CEB, now Gartner Leading organizations worldwide rely on CEB services to harness their untapped potential and grow. Now offered by Gartner, CEB best practices and technology solutions equip clients with the intelligence to effectively manage talent, customers, and operations. More information is available at gartner.com/ceb. To learn more, please contact: cebglobal.com/-legal 6