Evolve. Adapt. Lead. Succeed.
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1 Evolve. Adapt. Lead. Succeed. Canadian Centre for Ethics & Corporate Policy: Measuring the Effectiveness of Your Ethics Program Andrea Falcione Chief Ethics Officer & VP, Advisory Services SAI Global Compliance 13 September 2012 Copyright 2012 SAI Global, Ltd. All rights reserved.
2 2 Agenda Introductions Ethics Risk Management What Does Effective Mean? Measuring Program Effectiveness The Ethics Conundrum Possible Solutions Questions/Comments Copyright 2012 SAI Global, Ltd. All rights reserved.
3 3 Introductions SAI Global Compliance Multiple fully-staffed offices around the world Compliance Americas: 4 US locations Compliance EMEA: 2 UK locations Compliance Asia Pacific: 3 Australian locations 500 substantive clients, including 40% of the Fortune 100 companies and 30% of the Fortune 500 Oversee programs across 120 countries and in over 60 languages In-house expertise in a full complement of advisory services, adult learning, and technology integration Copyright 2012 SAI Global, Ltd. All rights reserved.
4 4 Introductions (cont.) Team of lawyers, data analysts, technology consultants and professional writers Certified Compliance & Ethics Professionals Consult on various aspects of client programs, including: Compliance- and ethics-related risk assessments Code benchmarking, commentary and re-writing Cultural and awareness assessments Remediation of conflicts of interest Assessment of program effectiveness Training and communication benchmarking Conducting interviews and focus groups Copyright 2012 SAI Global, Ltd. All rights reserved.
5 5 Agenda Introductions Ethics Risk Management What Does Effective Mean? Measuring Program Effectiveness The Ethics Conundrum Possible Solutions Questions/Comments Copyright 2012 SAI Global, Ltd. All rights reserved.
6 6 Ethics Risk Management CEO/Board/ Sr. Management ACCOUNTABLE TO Legal Risk Reputational Risk RESPONSIBLE FOR Shareholders/Investors Employees Government Contractors/Agents Customers Public/Media/NGOs Channel/Distribution Partners Suppliers Customers
7 7 Ethics Risk Management (cont.) Demonstrate & Promote Legal & Ethical Business Conduct Create a Culture of Ethics Demonstrate & Maintain Appropriate Oversight Address Existing Risks Operating Practices and Procedures Policies, Guidelines and Directives Communication and Dissemination of Information Information Management and Maintenance of Records
8 8 Ethics Risk Management (cont.) Any organization s risk management activities their number, their type and their sophistication will depend upon many criteria:
9 9 Ethics Risk Management (cont.) A truly effective program identifies the key risk areas a company needs to address, based on: o Risk assessment in substantive areas, such as corruption, competition, intellectual property, and so on o Assessment of risks by business unit o Assessment of risks by geographical location o Application of effectiveness analysis frameworks, such as metrics, in key risk areas Business risk can be defined as follows: RISK = Probability of Occurrence x Severity Goal: ethics efforts should decrease both o Develop metrics appropriate to key risk areas to track increases & reductions in frequency and/or severity of ethics failures
10 10 Agenda Introductions Ethics Risk Management What Does Effective Mean? Measuring Program Effectiveness The Ethics Conundrum Possible Solutions Questions/Comments Copyright 2012 SAI Global, Ltd. All rights reserved.
11 11 What Does Effective Mean? There are various lenses through which an ethics program can be viewed to determine its effectiveness: Legal what do laws and regulations have to say about it? Comparables how do you compare? Aspirational what does your organization wish to accomplish? These lenses inform both qualitative and quantitative measures of ethics program effectiveness.
12 12 What Does Effective Mean? (cont.) Legal Lens Includes: Canada Corruption of Foreign Public Officials Act U.S. Sentencing Guidelines OECD Guidelines Other sources By Risk Area Regulatory/Enforcement Agency Case Law By Jurisdiction Canadian Provinces Other Countries Stock Exchange Requirements
13 13 What Does Effective Mean? (cont.) Comparables Lens
14 14 What Does Effective Mean? (cont.) Example: Morgan Stanley Declination to Prosecute Garth Peterson guilty plea Conspiring to evade internal accounting controls that Morgan Stanley is required to maintain under FCPA BUT Morgan Stanley was not prosecuted! Why not?
15 15 What Does Effective Mean? (cont.) Morgan Stanley: Constructed and maintained an effective system of internal controls Quickly launched internal investigation Voluntarily disclosed Cooperated throughout investigation
16 16 What Does Effective Mean? (cont.) Morgan Stanley Monitored transactions Randomly audited employees, transactions and business units Tested to identify illicit payments Conducted extensive due diligence on all new business partners Imposed stringent controls on payments made to business partners
17 17 What Does Effective Mean? (cont.) Morgan Stanley regularly updates policies to Reflect regulatory developments Address risks associated with Ø Gifts & entertainment Ø Meals, travel & lodging Ø Charitable contributions Ø Outside employment Ø Morgan Stanley requires written compliance certs Annual Code certification Annual disclosure of outside business interests
18 18 What Does Effective Mean? (cont.) Morgan Stanley frequently trains employees on policies and the law Morgan Stanley also frequently reminds employees about ABAC laws, policies and tenets Circulation of Code and policies Guidance on engaging consultants Addressing specific high-profile events/examples (e.g., Beijing Olympics)
19 19 What Does Effective Mean? (cont.) Now, ask: How would your program compare?
20 20 Agenda Introductions Ethics Risk Management What Does Effective Mean? Measuring Program Effectiveness The Ethics Conundrum Possible Solutions Questions/Comments Copyright 2012 SAI Global, Ltd. All rights reserved.
21 21 Measuring Program Effectiveness How do you determine program effectiveness? % of Clients Who Use Each Measure Source: 2011 SAI Global Client Benchmarking Survey
22 Measuring Program Effectiveness (cont.) 22
23 23 Measuring Program Effectiveness (cont.) Consider this again: % of Clients Who Use Each Measure Source: 2011 SAI Global Client Benchmarking Survey
24 Measuring Program Effectiveness (cont.) 24
25 25 Measuring Program Effectiveness (cont.) Qualitative: Aspects of ethics program which concern strategy and program structure, and which are not easily represented numerically Example: Proactive, annual education and communication plan, including topics, audience, methodology, etc. Quantitative: Aspects of ethics program which can be counted and represented numerically Example: Training completion rates *Both factors are important, but remember that numbers don t always tell the whole story!
26 26 Measuring Program Effectiveness (cont.) Standards and Procedures Internal Controls
27 27 Agenda Introductions Ethics Risk Management What Does Effective Mean? Measuring Program Effectiveness The Ethics Conundrum Possible Solutions Questions/Comments Copyright 2012 SAI Global, Ltd. All rights reserved.
28 28 The Ethics Conundrum REALITY: Ethics is not typically 100% owned centrally. A few examples: distribution network issues (sales); supply chain program (procurement); hotline reports (HR) CONUNDRUM: How do the CEO/Board know things are being handled holistically and appropriately across your organization? REQUIREMENT: Although Execution will likely be distributed, Measurement and Reporting should be managed centrally.
29 29 The Ethics Conundrum (cont.) To whom do you communicate effectiveness? Sales We communicate to the Board We communicate to senior management We don t communicate effectiveness We communicate to employees Source: 2011 SAI Global Client Benchmarking Survey
30 30 Agenda Introductions Ethics Risk Management What Does Effective Mean? Measuring Program Effectiveness The Ethics Conundrum Possible Solutions Questions/Comments Copyright 2012 SAI Global, Ltd. All rights reserved.
31 31 Possible Solutions 1.How should we approach it? 2.What should we measure? 3.What does it mean? Effectiveness of Initiatives DASHBOARD Reports (Senior Mgmt & Board)
32 32 Agenda Introductions Ethics Risk Management What Does Effective Mean? Measuring Program Effectiveness The Ethics Conundrum Possible Solutions Questions/Comments Copyright 2012 SAI Global, Ltd. All rights reserved.
33 33 Questions/Comments ANDREA FALCIONE, JD, CCEP Chief Ethics Officer & VP Advisory Services SAI Global Compliance 51 Sawyer Road Suite 510 Waltham MA M D F
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