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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program – Day 16 – Tailored and Effective Compliance Training

One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA, your specific company compliance program, and to create and foster a culture of compliance. While it seems axiomatic that compliance training is the mainstay of any best practices compliance program, the conversation around training has evolved over the years.

The importance of determining the effectiveness of your compliance program has been enshrined by the DOJ. The 2023 Update confirmed that the DOJ wants to see evidence of the effectiveness of your compliance program. This is something that many CCOs and compliance professionals still struggle to determine. Both the simple guidelines suggested herein and the more robust assessment and results provide you with a start to fulfilling the precepts set out by the DOJ, as you will eventually need to demonstrate the effectiveness of your compliance training going forward.

Three key takeaways:

1. How and why have you tailored your compliance training and how do you determine its effectiveness?

2. Try an “espresso” shot of training

3. Present your training in both local languages and a variety of media.

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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Innovation in Compliance

Compliance Professionals Adapting to Change: Industries, Regulations, and Beyond: Part 3 – Jessica Czeczuga on the Role of a Board of Directors in Training and Communications

Welcome to a special series sponsored by Diligent, where we look down the road at key issues in 2024 and beyond. In this series, I will visit with Nicholas Latham, Renee Murphy, Jessica Czeczuga, Yee Chow, and Alexander Cotoia. Over this series, we will consider compliant communications in regulated industries, managing conflicts of interest at the Board level, the Board’s role in compliance training and communications, navigating the current ESG landscape, and professional growth and mentorship in compliance. In Part 3, we review the role of a Board of Directors in compliance training and communications with Jessica Czeczuga.

Jessica Czeczuga is a seasoned corporate training and compliance professional, currently serving as the Principal Instructional Designer at Diligent. Jessica’s perspective on the importance of Board oversight in corporate training and compliance is shaped by her extensive experience and deep understanding of compliance programs. She emphasizes the crucial role of the Board in setting the tone for the organization’s culture, advocating for active communication from the Board about the importance of training to all employees. Jessica also suggests that the Board should be more significant in discussions about your organization’s compliance efforts, ensuring it meets its stated commitments. She views the Board as another group within the organization that requires tailored training and active involvement in promoting a culture of compliance. Join Tom Fox and Jessica Czeczuga as they delve deeper into this topic.

Key Highlights:

  • Driving Compliance and Training Messaging
  • Fostering Alignment Through Board Involvement
  • Assessing the Impact of Multinational Training

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture. For more information and to book a demo, visit Diligent.com

Join us tomorrow as we consider navigating the current ESG landscape.

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Blog

Jessica Czeczuga on the Crucial Role of Board Oversight in Compliance Training and Communications

I recently had the opportunity to visit with folks from Diligent. We look down the road at key issues in 2024 in a podcast series sponsored by Diligent entitled Compliance professionals adapting to change: Industries, Regulations, and Beyond. I was able to chat with Nicholas Latham, Renee Murphy, Jessica Czeczuga, Yee Chow, and Alexander Cotoia. Over this series, we discussed compliance communications in regulated industries, managing conflicts of interest at the board level, the board’s role in compliance training and communications, navigating the current ESG landscape, and professional growth and mentorship in compliance. In this post, we discuss the role of the Board of Directors in compliance training and communications with Jessica Czeczuga.

Jessica, the Principal Instructional Designer at Diligent, emphasized the need for the board to underscore the importance of compliance, communication, and training and to provide messaging to employees that reinforces the significance of completing training. One of the key takeaways from the episode was the idea that the board sets the tone at the top. The board’s priorities are seen as priorities by the rest of the organization. By prioritizing compliance, communication, and training, the board can foster a culture of compliance and ensure that employees understand the importance of these initiatives.

Jessica also suggested that boards should consider providing messaging directly to the general population of their organization, highlighting the importance of completing training. This can help drive the messaging deeper into the organization and ensure that employees understand the significance of their training obligations.

We also discussed the need for boards to assess the effectiveness of training programs, particularly in multinational corporations. Computer access and language barriers should be considered when evaluating training effectiveness. By understanding employees’ challenges in different regions, the board can make informed decisions about training programs and ensure that they are effective and accessible to all employees.

Regarding board oversight of training, there are tradeoffs and challenges to consider. On one hand, the board must clearly understand the compliance program and what is required to support it. This may involve requesting additional metrics and information from the individuals responsible for training. The board can provide better oversight and support by having a deeper understanding of the program.

On the other hand, the board needs to strike a balance between oversight and micromanagement. Boards should trust the individuals responsible for training and compliance to do their jobs effectively. Micromanaging can hinder the effectiveness of training programs and create unnecessary bureaucracy.

We highlighted the importance of board oversight in corporate training and compliance. The board is crucial in driving compliance and training messaging throughout the organization. By setting the tone at the top and emphasizing the importance of compliance, communication, and training, the board can foster a culture of compliance. Additionally, the board should assess the effectiveness of training programs, considering factors such as computer access and language barriers. Balancing oversight and trust is essential for effective board oversight of training and compliance.

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture. For more information and to book a demo, visit Diligent.com

Join us tomorrow as we consider navigating the current ESG landscape.

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Creativity and Compliance

Creativity and Compliance – An Ounce of Prevention

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.
Ronnie’s company, Learnings, and Entertainment, utilizes the entertainment devices people use to consume information in their everyday, non-work lives and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies, and resources more accessible. Today, Ronnie and Tom, as they consider compliance training and communication, are being used in the best, highest use, and most effective manner.
The topic of shifting compliance programs towards prevention and engagement is compelling, as it challenges the traditional reactive approach and advocates for a more proactive, engaging strategy. Ronnie believes that most compliance programs are reactive rather than proactive. He argues that a shift towards prevention, communication, burst learning, and leadership development can mitigate risks more efficiently and make compliance training more interesting and positive. Tom echoes this sentiment, emphasizing the need for engaging, entertaining, and impactful compliance programs. He suggests that by focusing on prevention, communication, shorter training, and leadership development, companies can create a culture of psychological safety and reduce the time and money spent on investigations and problems.

Join Tom Fox and Ronnie Feldman on this Creativity and Compliance podcast episode as they delve deeper into this fascinating topic.

Key Highlights:

  • Shifting Towards Prevention: The Key to Effective Compliance
  • Using Comedy to Transform Compliance Training
  • Engaging and Time-Efficient Micro-Learning Modules
  • The Importance of Proactive Compliance Measures

Resources:

Ronnie

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31 Days to More Effective Compliance Programs

One Month to More Effective Compliance Through Innovation: Day 6 – Future of Compliance Training

Where is compliance training headed? In the 2020 Update, the DOJ stated, “companies have invested in shorter, more targeted training sessions to enable employees to timely identify and raise issues to appropriate compliance, internal audit, or other risk management functions.” While this tactical solution has proven useful, I wanted to consider the broader compliance training themes that compliance professionals have learned over the past few years to gain insight into where compliance training may be headed. I sat down with Shawn Rogers, Senior Director, Global Ethics & Compliance at Stanley Black & Decker, Inc., to provide some thoughts on the veiled land of the future of compliance training.

Compliance training needs to get to the point where managers and leaders drive compliance training based on how they perceive the risks in their organizations. In other words, an awareness of risks can permeate the organization to such a degree that managers will be able to recognize when their employees need training and can call on the compliance function to provide custom training opportunities.

Three key takeaways:

  1. Business crises almost always begin with a culture failure.
  2. Focus your most detailed training on those employees who are truly high-risk.
  3. This is the “just-in-time” training model that provides training exactly when and where the employee needs the information.

For more information, check out The Compliance Handbook, 4th edition, here.

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FCPA Compliance Report

FCPA Compliance Report – Carlos Villagrán Muñoz on Implementing Effective Compliance Programs in Latin America

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Carlos Villagrán Muñoz, Chief Compliance Officer at CMPC in Chile. We discuss operationalizing compliance at CMPC and in Latin America.

Carlos Villagrán Muñoz is a seasoned Chilean attorney with considerable experience in implementing and advancing compliance programs in Latin America. His perspective on the subject is shaped by his extensive experience and understanding of the unique challenges in the region. Carlos identifies two major hurdles in implementing effective compliance programs in Latin America: the need to tailor programs to both global and local contexts due to cultural nuances and differing perceptions of corruption and the pressing issue of money laundering, fueled by illegal activities such as corruption, drug trafficking, and human trafficking. He believes that Latin America lags in anti-money laundering efforts, which are crucial in combating corruption, and advocates for compliance programs that address these issues while considering cultural differences. Join Tom Fox and Carlos Villagrán Muñoz as they delve deeper into these topics and more in this episode of the FCPA Compliance Report podcast.

 Key Highlights

·      CMPC’s Compliance Program Addressing Antitrust Infringement

·      Navigating Cultural Nuances and Money Laundering: Compliance Challenges in Latin America

·      CMPC’s Comprehensive Compliance Training Program

·      The Rise of Technologically Savvy Compliance Experts in Chile

·      Dynamic Networking Opportunities for Compliance Professionals

Resources

Carlos Villagrán Muñoz on LinkedIn

The FinCEN Report Company

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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FCPA Compliance Report

FCPA Compliance Report – Peter Grossman and Duane Stumpf on Crafting Impactful Compliance Campaigns

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Peter Grossman, Co-Founder, Chief Strategist at Labyrinth Training, and Duane Stumpf, Global Head of Integrity and Compliance at Alcon.

Starting with a 70s-style rock and roll music number, Alcon Vision’s interactive, animated compliance training program, developed in conjunction with Labyrinth Training, has been recognized with high praise, receiving an Anthem Award and two Telly Awards. This program was created to make the company’s Lens Policy more memorable and engaging.

This podcast episode focuses on creating impactful campaigns and stresses the need for creativity, mission, and quality work. This episode features Tom Fox, Peter Grossman, and Duane Stumpf discussing how the program’s success effectively delivers important lessons in ways people will remember and enjoy. Through this episode, the trio offers great insight into developing meaningful campaigns that will have a lasting impact.

Key Highlights:

  • The Lens Policy
  • Creating Compliance Storytelling
  • Compliance Training Musical
  • Dr. Louis’ Musical Number
  • Award-Winning Compliance Training
  • Creating Impactful Campaigns

Resources:

Peter Grossman on LinkedIn

Labyrinth Training

Duane Stumpf on LinkedIn

THE LENS

CALL DR LOUIS

Tom Fox

Threads

Instagram

Facebook

YouTube

Twitter

LinkedIn

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FCPA Compliance Report

FCPA Compliance Report – Maria D’Avanzo on the Intersection of AI, ChatGPT and Compliance

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In the latest episode of FCPA Compliance Report, Maria D’Avanzo from Traliant returns to discuss the intersection of AI, ChatGPT, and compliance. The recent Federal Trade Commission investigation into OpenAI serves as a reminder of the importance of staying up to date on the latest developments in the field of AI technology and the potential implications of such developments. With AI and Chat GPT being powerful tools that can automate processes and generate content, organizations must implement AI Policies and Training to ensure these technologies’ safe and responsible use. AI Compliance Training is necessary to educate employees on the risks posed by AI technology and to guarantee that their compliance program is robust and effective. Organizations must create a comprehensive policy and provide ongoing training to ensure AI’s safe and responsible use.

Key Highlights:

  • AI and Chat GPT Consequences
  • AI Policy and Training
  • Creating a Policy
  • AI Compliance Training
  • FTC OpenAI Investigation

Resources:

Maria D’Avanzo on LinkedIn

Traliant

Tom Fox

Threads

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Report from IMPACT 2023

Report from IMPACT 2023 – Ronnie Feldman – Engaging a Global Workforce: Creative Solutions

ECI’s IMPACT 2023 was one of the leading compliance events in 2023. At this conference, Tom Fox, the Voice of Compliance, was able to visit with several of the speakers, exhibitors, participants and one group of ethically minded Girl Scout Troop. In this limited podcast series, Report from IMPACT 2023, Tom explores many of the most cutting edge topics in ethics and compliance through short podcast episodes. Check out the full series of interviews. You will be enlightened, informed and come away with a fuller and more thorough understanding of the most cutting-edge topics in ethics and compliance. In this episode, Tom visits with Ronnie Feldman, founder of Learning and Entertainments.

Tom and Ronnie discuss using creative solutions to engage remote employees, such as short commercials and social media style content. They chatted about corporate social responsibility and how to engage a global, multicultural workforce. Ronnie believes that e-Learning is mostly ineffective, long, and boring, and suggests using animation, music, and custom videos with real people in their language as creative solutions. Tom recommends pushing out a video of a certain style for a couple of weeks, then trying a different video of the same style for a couple of weeks, knowing that over time, more people will be engaged. They also discussed the importance of content being interesting, positive, and culture-based, but not preachy.

 Highlights include 

·      Global Engagement Strategies

·      Engaging Remote Employees

·      Creating Video Content 

Resources 

Connect with Ronnie Feldman on LinkedIn

Learnings and Entertainments

Connect with Tom Fox on Linkedin

Categories
Compliance and AI

Mastering ChatGPT: Part 3 – Revolutionizing Education and Compliance Training

Welcome to a special five part podcast series on mastering ChatGPT. My special guest throughout this journey is Larry Roberts, an accomplished professional with over 25 years of multifaceted experience. Having initiated his career in the corporate training sphere, he exhibited a remarkable shift to IT, contributing greatly as a Business Intelligence Analyst. His proficiency lies in harnessing predictive analytics for inventory and sales projections, which led him to tap into the realm of AI. In 2021, Larry chose to cozy up with podcasting and content creation. His tryst with ChatGPT began in November the same year and he has been fully engrossed with it since then. His insights into data models, large language models, and his overall passion for AI are certain to illuminate any forum. In this Episode 3, we look how ChatGPT can transform education and what this will mean for compliance training.

As we confront the digital age, educators, teachers and even communicators can no longer afford to be left behind. The rise of AI in education, epitomized by tools like ChatGPT, opens new frontiers in delivering accessible, affordable, and advanced learning experiences. However, this isn’t without complexities. There are pertinent steps to be taken – setting clear expectations, aligning AI with institutional policies, maximizing the collaborative capabilities of AI, and ensuring human oversight in AI implementation. By so doing, we can create an enriching learning environment that contributes positively to personal and professional development. In this episode, we explore these issues and others in considering how this will impact compliance training and communications.

In this episode, you will be able to:

·      Unlock key strategies to optimize your use of ChatGPT.

·      Acknowledge the importance of crafting a suitable persona and forming the right stage for elevated outcomes.

·      Unravel the issues corporate compliance functions may encounter while using ChatGPT, shedding ample light on effective solutions.

·      Learn how one can effectively utilize ChatGPT in making speeches and presentations.

·      Prognosticate the prospective impacts of ChatGPT and AI on the future compliance training landscape.

Key Highlights        

·      Setting Expectations

·      Limitations for Corporations

·      Leveraging Chat GPT for training

·      The Human Element and AI

Resources

Larry Roberts

Larry Roberts on LinkedIn

Red Hat Media        

Tom Fox

Instagram

Facebook

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LinkedIn