Speak Up! Encouraging and Responding to Employee Reporting Society of Corporate Compliance and Ethics 29 April 2011 Chicago, IL USA
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1 Speak Up! Encouraging and Responding to Employee Reporting Society of Corporate Compliance and Ethics 29 April 2011 Chicago, IL USA Maurice L. Crescenzi, Jr. Officer
2 DeVry s Global Organization Guidance. Collaboration. Excellence.
3 Speaking Up Program Objectives Empower employees to know why, when, and how to speak up Encourage employees to come forward in good faith without fear of retaliation Ensure matters are logged, tracked, and closed out in a robust case-management system Ensure that all matters are reviewed or investigated consistently, efficiently, and effectively Close-outs, reporting, and trending Guidance. Collaboration. Excellence.
4 Speaking Up: Program Components Code of Conduct and Speaking Up Policy Trending, Analysis, and Reporting Training, Communications, and Awareness Materials Speaking Up Program Investigations and Case Management In-take Systems and Mechanisms Centralized GCE Case Management System Guidance. Collaboration. Excellence.
5 Speaking Up: Program Components Trending, Analysis, and Reporting Investigations and Case Management Code of Conduct and Speaking Up Policy Speaking Up Program Training, Communications, and Awareness Materials In-take Systems and Mechanisms Encourages a culture of compliance and ethics Establishes expectation that employees should ask legal, policy, compliance, and ethics questions; raise concerns; and report suspected wrongdoing. Explains Speaking Up systems and mechanisms. Zero-tolerance regarding retaliation. Zero-tolerance regarding bad-faith reporting. Centralized GCE Case Management System Guidance. Collaboration. Excellence.
6 Code of Conduct and Ethics
7 Tone at the Top
8 Speaking Up Chapter
9 Setting the Expectation
10 Defining Compliance and Ethics Issues
11 Defining Employee Relations Matters
12 Speaking Up Resources
13 Anonymity and Confidentiality
14 Zero Tolerance
15 Speaking Up Ticklers Throughout
16 Compliance Policies Code of Conduct and Ethics Compliance Policies Guidance. Collaboration. Excellence.
17 Speaking Up Policy Guidance. Collaboration. Excellence.
18 Speaking Up Policy Establishes expectation of employees to come forward Encourages the first stop to be a discussion with manager Reminds that employee-relations matters should be directed to Human Resources Provides other Speaking Up channels: Manager s manager Human Resources Law Department Compliance and Ethics HelpLine or HelpSite Zero tolerance for retaliation and bad-faith reporting Anonymity and confidentiality Managers responsibilities Guidance. Collaboration. Excellence.
19 Speaking Up: Program Components Trending, Analysis, and Reporting Code of Conduct and Speaking Up Policy Training, Communications, and Awareness Materials Employee communications Awareness and instructional posters, brochures, etc. Information on Compliance intranet site Included in e-learning courses Speaking Up Program Investigations and Case Management In-take Systems and Mechanisms Centralized GCE Case Management System Guidance. Collaboration. Excellence.
20 Maurice L. Crescenzi, Jr. Officer
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24 In-take Systems Trending, Analysis, and Reporting Code of Conduct and Speaking Up Policy Training, Communications, and Awareness Materials Manager Manager s manager Human Resources Law Department Global Compliance and Ethics Department Compliance and Ethics HelpLine or HelpSite) Speaking Up Program Investigations and Case Management In-take Systems and Mechanisms Centralized GCE Case Management System Guidance. Collaboration. Excellence.
25 Awareness Materials Employees encouraged to ask questions and raise concerns Several speaking up resources: Manager Manager s manager Officer DeVry Legal Human Resources Compliance and Ethics HelpLine / HelpSite. Employee-relations matter should be referred to Human Resources
26 Speaking Up Program
27 Speaking Up: Program Components Trending, Analysis, and Reporting Code of Conduct and Speaking Up Policy Training, Communications, and Awareness Materials Case management system allows us to collect, categorize, prioritize, and relay all intake to SMEs for handling. Categories are subdivided by priority / severity Case management system can send copy of reports to key stakeholders. Speaking Up Program Investigations and Case Management In-take Systems and Mechanisms Centralized GCE Case Management System Guidance. Collaboration. Excellence.
28 Case Management System Case-management system managed by Global Compliance and Ethics Cases routed to appropriate departments / SMEs for review and handling Close working relationship with key functions, like Human Resources Other functions leverage same case-management platform More efficient routing and handling of cases Macro trending and reporting Guidance. Collaboration. Excellence.
29 Speaking Up: Program Components Trending, Analysis, and Reporting Code of Conduct and Speaking Up Policy Training, Communications, and Awareness Materials Case Management and Investigations policy establishes consistent practices related to the whens, whos, and hows related to investigations. Speaking Up Program Investigations and Case Management In-take Systems and Mechanisms Centralized GCE Case Management System Guidance. Collaboration. Excellence.
30 Case Management and Investigations Policy Cross-functional effort led by Sets forth the principles that should be adhered to for all formal investigations Lays out the steps that should comprise any formal investigation Determine the need for an investigation Identify the lead investigator Outline the case Notify appropriate members of management Develop investigations plan Gather documentation and conduct interviews Write report Follow up Guidance. Collaboration. Excellence.
31 Closing the Ethics Loop Formal report and executive summary Share findings with key members of management and Human Resources Investigator recuses himself / herself from discussions related to discipline Case closed in the case-management system Officer follows up with reporter Guidance. Collaboration. Excellence.
32 Speaking Up: Program Components Trending, Analysis, and Reporting Speaking Up Policy Training, Communications, and Awareness Materials Case management system allows case manager to identify trends. Robust report generating. Case manager connect trends to ERM process Speaking Up Program Investigations and Case Management In-take Systems and Mechanisms Centralized GCE Case Management System Guidance. Collaboration. Excellence.
33 Reporting, Trending and Measuring Quarterly reporting to the Audit Committee of the Board Top-line numbers Potentially significant matters called out in more detail Cross-functional Business Process and Risk Management Team Compliance and Ethics data shared Trends identified and relayed to SMEs Action plan developed by appropriate SME or leader Survey Guidance. Collaboration. Excellence.
34 Overview Thank You Maurice L. Crescenzi, Jr. Officer Mcrescenzi@devry.com
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