FacultyFaculty/Author Profile

COMPLIANCE CODES, TRAINING AND COMMUNICATION


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REBECCA: And we're going to go straight to the next panel. So if we could move onto codes, training, and communications and get Herb, Shawn, and April up here. Thanks, [INAUDIBLE]. That was awesome. We're going to start with the video? No. I guess it's loaded. Oh, because we didn't have another one.

[SIDE CONVERSATION]

So guys, we're going to start with the polling question for the control room. Thank you. It should be on your screens now. So please feel free to go ahead and respond to the polling question while I introduce our panelists.

This is always one of the more fun panels. We're talking here about the part of the program that really impacts every single employee at your organization. It touches every employee at your organization. Your code, your training and communications. These are your efforts to really reach hearts and minds, so incredibly important part of a program, and fun.

And we have such a great panel to talk about it. I'm so excited. You guys, we have such fabulous panelists for this program. I really am blown away by the level of expertise on every single panel. And so to talk about codes, training, and communications, we have April Oliver, who is the Vice President and Associate General Counsel for Global Ethics and Integrity at Salesforce. April manages their entire program, working directly with senior members of the business leadership team, including the C-suite.

Next up is Shawn Rogers, who's the Lead Counsel for Compliance Training and Communications at General Motors. Prior to joining GM, Shawn was the Director of Global Ethics and Compliance at Western Digital in Irvine, Andrea's job now. So he passed that along-- thank you-- and Director of Compliance at the American Bureau of Shipping in Houston.

And we also have Herb Wilgis, who's the Director of the Office of Legal Compliance Programs for Microsoft Corporation. Before joining Microsoft, Herb was a partner at K&L Gates, and before that was a prosecutor.

We're so happy to have all of you here with us. We're going to start, as we've been doing, with this polling question. How do you measure the effectiveness of compliance and ethics training at your organization? A, we test employees during training. B, we ask employees about the effectiveness of training through survey questions at the end of the training. C, we test employees on the subject matter at some period following the training. Or D, we just hope for the best. And that's been many organizations' method for many years.

So it looks like-- oh, so most of the respondents test employees during the training. There are a few who don't do any testing. And this has really been an area that's difficult, that's challenging, right? How do we know that what we're doing is effective? So I'm sure that's something that our fabulous panel is going to touch on. And then with that, I'm going to turn it over to you three.

APRIL OLIVER: Thanks so much. And Rebecca has asked me to both moderate and be a panelist, so bear with me here. I'm going to have a few comments and then ask some questions to my fellow panelists here. Thank you so much for coming out.

This appeals to the geek in me. I get really excited about this because I really see the code of conduct as a living document. And it's not only just a living document, it is a document that is your best friend as a compliance leader in terms of building your brand at a company.

I was given a gift when I joined Salesforce five years ago because one of the internal audit action items when I arrived was create a new code of conduct. And I didn't know anybody at this new company. I had to go around and figure out how was I going to do this as a new person at this great big fast-moving company.

And I realized I hit upon this idea of having a multi-stakeholder panel and meeting all these different people, bringing them together at a weekly cadence, and really getting their buy in at the front end, which saves a lot of problems at the back end when you're trying to roll things out.

So as I think about the different code iterations that we've had at my company, I would encourage you not to make it a one-person affair, but to leverage the work off of other departments and use it as a leadership exercise not just for yourself, but to really cast the seats at the table of other people who are up and coming leaders in the company that you will depend on during your tenure as a compliance lead. It really is a wonderful opportunity for your brand.

So with those first initial comments, why don't I pass it onwards for you all to do some opening remarks.

SHAWN ROGERS: Great. I've been focused on training, and I want to say that what you just said about developing the code applies the same for developing a comprehensive compliance training program. When I came on board at GM to do the training program, I realized that our risks were much more broad then just anti-corruption, which is kind of the traditional risk in the code risks.

We had safety risks. Our DPA and our monitorship was about safety violations. We didn't violate anti-corruption laws to get a monitor. We had a safety issue with our ignition switch matter. And so we had to look holistically and say we want to have a cross-functional training program, just like you mentioned with the code.

And so we got stakeholders from product safety, from workplace safety, from IT because they have the cybersecurity risks. We had people from ethics and compliance to deal with the code risks and the anti-corruption risks. And we also pulled in stakeholders from HR because we had the MeToo movement hit about the same time, and they had, obviously, the anti-harassment and anti-discrimination risks.

And so we created, actually, a steering committee to help us develop our training program just like what you said with the code. And that cross-functional governance has proven to be very valuable in terms of getting buy in, in terms of getting resources, and in terms of making it a broadly accepted program that looks like it comes from GM as a corporation rather than the ethics and compliance function.

HERB WILGIS: Thanks. So you know, I approach this area with a fair degree of humility because I think one of the things that a lot of companies are learning about their training programs is they're not very good in the sense that they're not very effective. And it's a significant part of every company's compliance budget.

And so a lot of companies are reengineering the space. GE with Al Rosa has some interesting things he's doing that I can talk about in a little bit. We've completely changed our training program. But I think for anyone doing a compliance training program, there tends to be a focus-- if you think about the what, when, where, how, and why-- there tends to be a focus on the how. And so everyone's talking about well, we need to do gamification now, or online training doesn't work, or in-person training doesn't scale. And so there's a lot of focus on the how.

But I think you really have to start with the who and the when. And what that basically means is every single guidance that the government, that the regulators give about training talks about tailoring it to your risk. So you have to figure out what your risks are and then tailor the program to those risks. And frankly, don't spend a lot of time training on things that aren't part of your core risks. And that allows you to scale your program better.

The other thing is to think about when. So once you figure out what your risks are and who are your risk triggers-- who are those employees who play a role in those risks-- then you have to figure out when you're going to deliver training to them. And once you figure that out, I think the how and the what gets very simple. But I think doing that initial risk-based training approach is super important.

APRIL OLIVER: So those were great comments and really great to hear your expertise here. Why don't we start, though, with the drafting challenge because I think the drafting challenge is not insignificant. I can't tell you-- as part of our program, we diligence lot of partners. And very typically our feedback is looks OK, but you need a code of conduct. We're not going to take you on as a partner unless you have a code of conduct. And they're like, what is a code of conduct?

So for me, the answer to that question is incredibly important as part of our risk mitigation policy, FCPA-type issues that we were just all hearing about. I think that, for me, one of one really important point is that do codes of conduct have to be complex? Have you seen short codes of conduct that work for you, or that address the risks? I'd be interested to hear your responses.

I do think the answer to that question depends on whether you're pre-enforcement action or post-enforcement action. So some thoughts on drafting.

SHAWN ROGERS: So drafting the code. We engaged an outside consultant to help us do this, a well-known player in the compliance space. And we did it as part of the compliance program overhaul that came along with the corporate monitorship that we received back in 2015. And again, we had to look holistically at all the risks that we face as a company, and not just those that are traditionally owned by the compliance function.

Our code is very much safety-centric, but it also covers all of the traditional risks that we've mentioned today and yesterday during this presentation. And we had to focus on usability and readability. Our previous code was OK. But if you read into it closely, you'd see that it was drafted by people who were familiar with legal drafting. It had some lawyer speak in it.

And I think a good compliance function, a good compliance officer will have the ability to look at the law and the legal aspects of what you're trying to enforce, but then translating it into the language of the business so that your lay person who's reading the code will have an understanding of what you're trying to tell them.

One of the common things I always say is my target audience, I don't care if they know how to spell FCPA, OK? It doesn't matter to me. What I want them to be able to understand is what is our position around gifts and entertainment? What are the parameters? And so as you draft the code, you look at the law, and then you say, what's our policy, and you write the code to teach to your policy in the language that the business will understand.

And having it colorful and photographs that reflect the company and branded with a company-- I think that those things all add up to an engaging code , rather than just a black and white document that is very legalistic. And so those are some principles that we tried to do it at GM with our new code.

HERB WILGIS: Yeah, I think your code is-- most of all, it's a cultural document. And you know, from a compliance perspective, we had this transition in our company with our new CEO, Satya Nadella, coming in a few years ago. And Satya's first real bet as a leader was focusing on the culture at Microsoft. And one of the things he likes to say is we want to have a learn it all culture rather than a know it all culture.

And when we redrafted our code a couple of years, we really focused on what's the mission at Microsoft. And the mission is to empower people to do more, and the way we empower people to do more is by building trust. We have a trusted cloud. We have trusted privacy and security. And so we've organized our code around how do you build trust with customers, with regulators, with our partners and suppliers, and with ourselves as well as the financial community when it comes to our books and records.

And so one of the things we did in tandem with redrafting our code was to simplify our policies. So we had about 1,800 corporate policies, and we simplified or eliminated over 90% of those. We now have about 150 because we found if your employees can't understand your policies, then you're going to be in trouble. And when lawyers have debates over the meaning of a policy, that's a sign of an ineffective policy. And we want employees to use our policies and our codes as sort of guardrails on a highway, as opposed to conflicting directional signs that end up paralyzing your employees.

And ultimately, when I think about an employee in an ethical gray area about to make a bad decision or a good decision, I don't necessarily want them thinking where do I find the policy that addresses this subject. I want them thinking what are the values and what's my culture that addresses this issue. And the simple question, does this hurt trust with my customer or does it build trust is often the answer to a lot of ethical dilemmas without the need to go back to the ethical sales policy.

APRIL OLIVER: So great points. I will say that the culture aspect is paramount, and it really is a cultural exercise each and every time. We do a code refresh just about every single year. And when we do that, we're not just looking at law. I mean, obviously, this past year GDPR was a huge influence. We had to look at our privacy section very carefully and redo.

We also-- because we have a growing public sector business-- decided that we need a public sector addendum. The rules governing people inside the public sector are even higher, in many instances, than just in the commercial sector. So we gave careful scrivening to that section. But most importantly, we did a hard look at the values section and realized our company had gone out and commercially stated the importance of not just trust and innovation, which are paramount at our company, but also the importance of equality.

And I really wanted to call that out, that this is a deep value in a legal sense. It is a value that we all attest to when we join the company. And it's also something that we do stress in our in-person trainings. This is a document that I see as the backbone of the company. All the other policies are the rib cage, the trainings are rib cage. But if you get the code of conduct right and it reflects the culture, it reflects the values, it reflects the voice, you have a compliance program. That is the first document that you need to get in order.

So completely agree with the points there. I wondered if you could talk a little bit-- both of you are large companies. We are not as big as you all, but growing very fast. And one of my challenges over the past five years has been internationalization. There are some pitfalls and challenges with internationalizing.

One thing I did try to do at the front end when I was building our stakeholder governing board was cast it with folks from other cultures and other countries because I don't want the code of conduct to be an imposition of HQ culture on them. I want them to have a seat at the table. What are your thoughts on internationalizing a code of conduct?

SHAWN ROGERS: I agree. It's very cultural, and you need to understand where you're located and where you're doing business and what your audience is like in those areas. Obviously, translation is a big deal and getting the translation right. And I think translation's always one of the most difficult part of developing a global document simply because of the number of reviews that it has to go through. And then when you do the translations, you get the translator's version of the language and not the company's culture reflected in that.

And so it's very important to have local language reviewers as well. But also the imagery, the photography, the other elements, the aesthetic elements of the code tend to make it more inclusive if you use a very diverse set of images and culture references.

Yeah, that is a challenge internationally, especially when you've got a dynamic business. We recently sold off part of our European division at GM, and so we had some languages that then became irrelevant and we lost a few brands. So we had to actually redo the code just to adopt to that major shift. So you have to have some degree of flexibility and be nimble with your code.

And so I think revising it quickly and frequently to adjust to the ever-changing business, that sends a signal that you know what, this is a dynamic document. You need to keep aware of it. You don't just read it once and put it on your shelf.

APRIL OLIVER: Exactly.

HERB WILGIS: Well, one of the advantages of being at a big company is we have this team at Microsoft that reviews content for geopolitical risk, mainly because when you're shipping products you need to be sensitive to borders and the use of flags and imagery. And so we run the code through them and we find out all kinds of interesting things, like don't show someone with their feet on the desk. Don't show someone patting the head of another person. And I think that's a very important review to do so that your images aren't offensive.

I do think when you think about making your code local, one of the things that's very positive is when leaders in subsidiaries talk about the compliance program and communicate the code, is that they actually have it with them. So we actually, in a somewhat old school way, make a lot of copies of our code. We have a nice booklet, and we handed out to all of our country managers.

And we ask them, when they're leading trainings in the subsidiary or have an all hands, to actually use this document because it is a very easy guide to making good decisions in ethical gray areas. So I think the communication of the code is where you really get the local impact.

SHAWN ROGERS: Just to go back to the cultural thing, here's something that happened at GM that you would never suspect. We found that the term red flag, which we used all over the place, had a cultural sensitivity in China because they obviously have a red flag. And they came back and said, use something else. Don't say red flag because we think it means you think all the bad stuff happens in China.

And so we had to get rid of the term red flag, which we used all over the place, and we said warning signs or ethical warning signs, or something like that. But that's just a little nuance that we became aware of, and we were totally oblivious to that in the early drafting of our policies and our code.

APRIL OLIVER: Such an important point, because that little nuance has big repercussions in a potentially high risk area. So a whole group of people could have opted out just by the signals you're sending. I do think that the cultural hearts and minds is such a key point.

Along with sort of online training that we push out to everyone in the company in many languages, we also do a boot camp. And we have selected out our sales team, sort of the sales boot camp, as well as our solution engineers to get very early training in person in very dynamic format, dynamic in the sense of scenario-based, maybe three sentence long hypotheticals which may or may not be real, from real life.

But as part of that precursor to that training, which is very interactive and early in a person's tenure, we talk a little bit about what a dynamic, living, breathing code of conduct means. And I or whoever's during the training will say how many of you have actually read your code of conduct?

And you know, typically maybe half the room will raise their hand. And then I look at them, I said, well, think about it this a minute. I mean, I recognize it's a stack of paper. You're getting a whole lot of paper and lot of things to read. But this is a document that you've signed that you've attested to knowing. And it's a document that is posted externally to our customers. It's a document that the government's going to read when they come in and if they come in to do an investigation. So it's going to be the document that they judge us by.

But finally it's the document the investigations team is going to use. So if and when you see us not in a training context, but more in an investigations context, this the first thing that we go to to see if whether or not something that you've done is improper against our code of conduct. We get very good buy in after that when we explain the personal hook and what's at risk. And almost universally people will come up and thank us for explaining the actual relevance to them personally for the code of conduct adherence.

So any comments? How do you get people to really personally care and give more than just lip service to the code of conduct?

HERB WILGIS: Well, I think I would use that to sort of segue to sort of a training point. And that is when we decided to reengineer our training program, we thought about our code of conduct training, which at Microsoft is required of every employee every year. It's a real opportunity to capture mindshare with employees.

We have an hour. We don't use all of it, but it's announced by our president. Every member of the leadership team is responsible for launching it to their employees and driving 100% completion. And we thought about, you know, this is a lot of money. This is a lot of time. Should we continue to do code of conduct training or place those resources in more targeted, just in time training?

And what we decided was that the code of conduct is so important and this is such a great window, we can't lose this moment. And so we reengineered the training. It's always gotten good reviews from employees, but we reengineered it to make it much more dramatic and interesting, more like a TV series.

And we really decided, instead of focusing on employees making mistakes, which was kind of our approach-- we show an employee thinking through a problem and making a mistake, and then we come in and say, this is how the person should have done it-- we took the approach of actually being very transparent with our employees about ethical gray areas and showing employees struggling trying to make that decision. And we hired actors and have a director.

But I just have a one-minute preview of it to give you a flavor of the new approach we're taking, if we could play that.

[VIDEO PLAYBACK]

- I was disappointed about the loss of some of my rewards.

- Nice to meet you too, Minister Kayohura. Is that a Seahawks Jersey?

- Are you sure you read my book?

- Did you know that Microsoft is one of the most attacked companies in the world?

- My team started calling me Mr. Security.

- You know you did the right thing by speaking out.

- Do you think that you're experiencing retaliation here at Microsoft?

- So as you can see, these Azure solutions are in the best way to accelerate your digital transformation agenda.

- Kayohura is going to be impressed. Let's not mention it to any other partners, OK? This one partner who seems to win all the bids [INAUDIBLE] supports. The deals involve higher than usual discounts that were flagged by our analytics tools.

[CHEERING CROWD]

- Touchdown Seahawks!

- Did you protect the data in your source code? Is everything secure?

- Wow. You really are Mr. Security now, aren't you?

[END PLAYBACK]

HERB WILGIS: So one of the things, when we did this, is this training kind of became a viral hit at the company. People were tweeting about it. They were bragging about it to other employees at other companies. We actually had companies calling us up and said your employees are bragging about their compliance training. Please tell me what you do.

Blind, which is an app where people complain about their employers, when I go on there, actually our code of conduct is actually reviewed favorably. They might say, well, my job sucks, but I like the code of conduct training.

So the theory behind this is that you're training-- whether it's a large-scale production like this, which is a couple hundred thousand dollars and high production values and all that, or whether it's something much smaller-- really reflects on who you are as a compliance group. And if your training is boring or you're not respecting people's time, that reflects, I think, poorly on you and whether people are going to raise concerns. If they think you can't do interesting training, why would they trust you with a concern?

So I think the approach has to be measured. And so after we did this code of conduct training, we sort of layered our approach to training, which is really based on we kind of went back and actually studied what is effective adult learning. It's called andragogy. And what we found is there's this thing called the Ebbinghaus forgetting curve, which basically means that as I'm talking, 40% of you will forget what I'm saying in the next five minutes. And 30 days from now, 90% of you will forget everything.

So if you think about a training program where there's going to be 90% failed retention, you have to come up with some different approaches. And what that really means for us is having shorter courses, building up what we call sort of a Netflix model of on demand short videos. If you think about people these days, no one reads the manual. When they want to know an answer to something, they just go online and they do a Bing search or a Google search and find it immediately.

So we wanted our compliance library to have these resources where people could just search on stuff, get a two-, three-, four-minute video and find stuff. And then we also are doubling down on in-person training. But a lot of the science behind training really talks about having the employee feel like they have some control over their training and that it's highly relevant to them. What they don't want to do is just be lectured at and feel like they have no control over whether they can exit or leave the course or use their time in other ways.

SHAWN ROGERS: So kind back to your question, and to tie it into what Her has said, if the code of conduct is important only to the chief compliance officer and the compliance staff, it's going to be a shelf document.

But if you can somehow get the message out that the code of conduct is important to the CEO-- if Mary is going to come out and tout the value of the code and use it in her messaging and give a strong opening letter in the code, and also, at the opening of the code of conduct training, if you can have a 1 one- to two-minute snippet of Mary telling the employees why the code is important-- then it becomes a company document that's important to the senior leader of the company. And then people kind of sit up and take notice. If Mary said it, that's one thing. If Jeff Taylor, the chief compliance officer, said it, that doesn't carry the same level of gravitas to the thing.

And so coming back to your retention, I was at a compliance event a couple of years ago in New York. And Alex Demetrief, the general counsel for General Electric, was there speaking. And he said 10 minutes of Jeff Immelt talking about ethics and integrity is better than 10 hours of ethics training pushed out to the company. And so if you can get your leaders to buy in and use that code as the central part of many of their messages to the employees, you're going to get a broader adoption, and people will take it more seriously.

APRIL OLIVER: And to really live and breathe it. You know, we are in the interesting situation of having two CEOs now. We have co-CEOs, and so we've got their buy in in our latest round of training. And they each have a different vision and have hit upon separate messages, but all revolving around values.

I want to deep drive for just a minute on a really practical issue that may seem a little bit boring, but it's important for people to think about as you're shifting and changing. And that is how do you, practically speaking, retire an old code of conduct? Have any of you ever done this exercise?

HERB WILGIS: No, we just revise it.

APRIL OLIVER: OK. So I will say just as a point, having gone through this a couple of times now, you really have to be very deliberate about archiving the old code in all of its various versions because you could still have investigations down the way where that old code is relevant, and you have to go back and know the text in whatever language, wherever in the world. So make sure you have good archiving system.

You also have to be somewhat disciplined about going out and finding every place in the world the old code exists online, whether it's your investor relations page or a compliance home page or other sites out there that you don't even know about. Do the banger Google search in terms of finding it and making sure that you're replacing wherever you can because you certainly don't want third party partner or a customer googling your code and pulling up that old thing from 10 years ago. So it is a piece of hygiene that you have to be deliberate about, particularly in this age of insurmountable data.

And it does go to pushing out-- then you've got the whole challenges of bringing in your new code. And why don't we talk about comms plans a little bit, communications. It sounds like both of you have been very intimately involved in not just designing training and thinking about training and producing training.

But I would think that communicating some stories about the training itself is really important. How do you practically do that, particularly if you're just a small team? I think so much of this, so much of the time, the answer's got to be how does one or two people do this as opposed to a whole great big team. Do you have any thoughts?

SHAWN ROGERS: So communications plans, yeah. My thinking on this has evolved because I came into GM primarily to look at the training function. But what I realized was that communications can't get a short shrift in the evaluation as well. There's a great quote by British philosopher Samuel Johnson, and he said people don't need to be as instructed as much as they need to be reminded.

And the reminder piece comes from the communications. The instructions come from the online course or the live course or whatever. And they will retain it to some degree, and as you repeat it they'll retain it more and more. But if you can come up with a way to remind people of their ethical obligations and the policies, that's critical.

And one thing that initially we neglected to do, we didn't align the code messaging with the training and with the communications. But what we realized was there are seasonal aspects to communications, where certain communications at certain times of the year we'll have more relevance to employees and what they're doing at that point in time.

And so as you look at your code of conduct, and then you decide what's going to be in the code course for this year, and then you decide what courses are going to be in the curriculum for the year, then you say, you know what, let's align the communications plan to reinforce that throughout the year and put it into a schedule that will match both the timing of the possible risk events, and also that will reinforce your training plans. So really, you tie your code, you're training, your communications together.

But you also, with communications, look for opportunistic things that happen that will help you reinforce your message. So look for an event that's in the news that says you know what, that company just got in trouble for doing something, and we have a similar risk here at GM. Let's use-- like my dad once said when I got in trouble, he said, I can always use you as a bad example. Don't worry, all is not lost. You can always use another company as a bad example of what not to do.

And so it needs to be nimble enough to be flexible, to be adaptable to the current situation, but also to reinforce the principles. And so I don't like to look at the code, the training, and the communications in isolation. I like to look at them more as a holistic big picture and come up with a deployment plan, a schedule, and a timing for each communications piece. And they become, then, mutually reinforcing.

APRIL OLIVER: Great points.

HERB WILGIS: Yeah, I think the danger with communications is looking at it as a standalone sort of program of your compliance operation. I mean, let's face it. Employees have so much noise and they get hundreds of emails a day. They're bombarded with information. So the inevitable email from the compliance officer, the only reason they open it is to find out who screwed up because they want the juicy stories.

And I think some compliance groups do that. I was once at a conference where someone said they published something called the Darwin Report, where they highlight employees who have screwed up so badly that they have been fired. And he just thought this was the greatest thing ever.

And I tend to think if you want your compliance function to not be viewed as the police department, you should really take an approach of focusing on lessons learned from compliance failures or misconduct of employees rather than a kind of making sport out of people's ethical misfortunes.

I think we're all probably familiar, in jobs we've had, where you get the letter or the email from a leader saying, make your numbers, it's really important this quarter, do this, do that. And then at the very end, there's a little sentence says by the way, you know, do all this with integrity or something like that.

So the integration of the message from the leadership is super important. And I don't think it really should be-- I mean, yes, it's important to have a schedule, perhaps as a quarterly message from a leader about compliance. But really it should be integrated in everything they say, and again, it goes back to that sort of cultural issue.

And for us, you know putting this formulation around trust, and does this harm or build trust, has been actually a really useful way for our leaders to talk about ethics and compliance because it's put it kind of in the language of succeeding not only in integrity, but succeeding in their business as well. And so that's one approach we've taken.

APRIL OLIVER: I got to tell you that just practically speaking, it is always important to us to get it done, and get it done within a certain time frame that we have because we do our code of conduct training every December without fail. That's just the period on the calendar that we've staked out.

But our year end is January. So I really do like getting it truly done because I never want to be in the position of impeding on quarter close or year end close because that's not fun to have to go bang on managers' desks and say your team's not done yet. Why? It's a choice between ACV and doing my code of conduct training. We don't want to put people in that position.

I will say that some of the online aspects of the training we've rolled out on our own platform form trailhead have made it much, much easier both to have comms as well as to drive completion rates because of the built-in dashboarding that every single manager can see who on his team has completed or not completed. So that allows for the ownership much more directly, as opposed to them all calling us up and kind of weighing us down with well, how's my team doing, and how's my team doing, and am I beating legal? And you know, it's that horse race aspect of it. They can take charge and signal and own.

And I will say before we pushed out the dashboarding on our own tool, we used to have to do this very laborious manual task of literally, at the end of the year, the 800 people who hadn't completed-- well, if I had a five-person team, we were all making 1,300 phone calls apiece to sort of drive the completion. With the dashboarding, this actually becomes the manager's responsibility.

And I'm not beyond internally, on certain select message boards, posting Beat by BU at certain intervals what the completion rate is because I do think competition does still exist at high levels among senior leaders, and no one wants to be the last to complete. I have noticed that we're a pretty acquisition-friendly company, and sometimes you have to give special love and attention to the new acquisitions who don't always fully appreciate how important it is to get this done and what an exercise in values it is. Do you all have any thoughts about acquisitions and codes of conduct?

HERB WILGIS: Yeah, I think that's a fascinating point. And I would extend it to new employees as well. All these people out there who are getting fired for misconduct from companies, many of them, they're moving on to other companies and they bring that culture with them. And similarly, new employees from acquisitions, and just new employees coming out of school, I occasionally go over to the University of Washington business school and teach a class on business ethics.

And I always take with me this video that I filmed of one of our employees who engaged in insider trading, was caught and prosecuted and went to jail. And he asked to make a video of his experience so other Microsoft employees could learn from his experience.

And so it's a very powerful video. I mean, he's crying and he's talking about the FBI executing a search warrant his house while his family is having dinner. And I show this to the business students, and their eyes are as large as saucers. And these are mature folks who've probably had a couple jobs already. And they just have no idea about insider trading, none, that you can actually go to jail for that.

And I think about that kind of knowledge gap for people coming out of schools. I think that also exists with other companies, depending on what their culture is. And you've got to make them understand when they come to Microsoft, there's a culture at Microsoft that is going to guide their actions, not the culture where they came from if they're running problematic parts of that.

But you know, culture can also be a tremendous gift from other companies' culture. Like when we hooked up with LinkedIn, for example, one of the ways they do their compliance training is-- what they say is we understand employees may want to go on to their next play after a number of years here, and we want encourage that.

And one of the ways in which we want you to skill up while you're at LinkedIn is to learn about ethics and compliance because if you want to be the CEO of a company or you want to go to a startup, ethics and compliance is a key part of your job. And so that's one of the ways they get employees to skill up in that area, which is a great approach.

SHAWN ROGERS: So when it comes to acquisitions, I think of our recent acquisition of Cruise Automation here in San Francisco that's doing the autonomous vehicles. I think a lot of what we do as compliance officers-- and not just in training and communication, but in everything we do-- is strategic partnerships, and really reaching out and creating a partnership with the key stakeholders.

And so what we did when we had the cruise acquisition, we reached out immediately to the senior leaders and said hey, welcome to the GM family. We do not want you to become GM. We want you to retain your personality, your nimble nature, your Silicon Valley entrepreneurship, and your skill set. But we need you to make sure that you line up your values and your policies and your codes and such with the parent company.

And so it was a partnership with us and the new leadership. And we basically said here's our source code. Here's our material that we use, and there are fundamental principles that we value at General Motors. And here's a legacy of history in the automotive industry that you don't have, and experience with safety and government agencies and such. We want you to be able to leverage this knowledge, but put the Cruise spin on it.

And so what we did is we basically handed them the courses and the training materials and everything and said, here you go. Keep the principles. Do what you want with the messaging, the packaging, the language, and put your personality into it. And so when you look side by side, you see the common threads running through the materials. But you see funky stuff coming out of Cruise, and you see old, stodgy stuff coming out of GM.

But at the same time, it's the same core principles and the values and the messages. And to me, that's what you would do with an acquisition is to bring them in as part of the family, but let them maintain their unique personality as long as they stay within the lanes.

APRIL OLIVER: It's such a great point and such a smart play. I think-- given all the acquisitions that we've done-- I do think whenever you're being acquired, there's fear. There is always fear. And while we may love the idea of an independent subsidiary, ultimately I'm not sure the SEC would ever think of anything that as anything but an oxymoron, right? So you need to get the GM spin on it, but you need the buy in.

And so what I've found will work when you're acquiring is you want them to do the online training. You have to make sure, as a technical matter, that they can get the online training because a lot of those systems are not necessarily going to be compatible. So that's like step number one with your integration team is well, are they online? Are they on our systems? Can they even log in to our trailhead?

And sometimes the answer to that is no. And if that is the case, then you have to go to Plan B. Well, what is Plan B? Is it a road show? Or do we do a centralized webinar in multiple languages so that we can reach out and not have a gap in time? But even before all of that, we have found that one of the most important things, particularly with small technology startups, is really introducing the function.

I mean, it's getting into the roadshow along with all the other functions, whether it's sales or whatever, and explaining what an ethics and compliance function does because for the most part, the smaller technology companies have been built up to grow ACV. And their book of business looks great, but maybe they haven't been building a program like this, and maybe their founders wouldn't even realize that careers like ours even exist.

So you have to really explain the importance of and what we do and what our resources are, get their buy in, have them become the advocate, and have them actually tell their people that this is important, I want you to listen to this. It's got my buy in. And if you can get that at the front end, I think the process of integration goes a lot easier.

I want to talk just for a minute about some unique challenges. I know that not everyone is-- is anyone here with a smaller company. Or are you all with big companies? Anyone? Anyone interested in some tips for smaller companies? I do think that in Silicon Valley, we have a lot of startups. Startups are known to have very long hours of work, work hard, play hard kind of environments. And that does create all kinds of potential code of conduct gray areas.

And so I do encourage-- I go out and talk a lot to cohorts. We have accelerators and so forth. And I actually say right from the get go, glad you're here. We're excited to participate with you. But you need your own code of conduct because we are not here to be mommy and daddy in this situation. You're a separate company. This is a great branding exercise. It's a great values exercise for you and your fledgling little company to decide what really matters to you and for you to own up and address those issues responsibly as they arise in those situations.

So even small companies, I think-- particularly in this MeToo era-- should have a code of conduct and think carefully about it. I'm a former Amazon alum, and one of my great lessons coming out of there was codes of conduct don't have to be long. They really don't. I think Amazon is a super large company. I won't venture to guess how many employees now. But their code of conduct is two pages.

And there's some profound reasons for that. When you're trying to internationalize all around the world in lots of different markets, lots of different cultures, it's easier to translate and do the local law analysis of a very simple code of conduct than it is a 20-page. It's also a lot cheaper.

So those are just some of my quick thoughts on really, simplification does matter a lot, and complexity can be your enemy. Another thought on startups and founders and sort of the founders' mindset actually goes to conflict of interest. And this is a really important point when you're having that first meeting, I think, with a founder and trying to socialize what is a code of conduct. Founders typically, more often than not, very creative, very innovative. Probably pretty large ego if they've just had a great big successful acquisition, so with all due respect, and they should be.

But all of a sudden their potential for conflict of interest has shifted radically when they're walking into the doors of a company like yours because you're a much bigger company, and their world of conflict of interest, up to the point of acquisition, had been small. It had been just their one product that you are acquiring. And now all of a sudden they're walking into a company where gosh, at Salesforce, we have a ventures company. So if a founder's coming in and he's got his own venture arm, well, that's a problem.

So we really do have to think carefully and explain and socialize the idea that this conflict of interest part of the code of conduct and our conflict of interest policy, you have to think afresh with each and every acquisition what sort of risks that poses. Any thoughts on that?

HERB WILGIS: Well, I think I have the luxury of a good budget. But I think if you look at compliance as kind of a heart and mind thing, I think your money, to the extent you have any, is well-spent in the training area because I think that's where you're going to win the heart and mind, particular if you're taking a cultural values-based approach.

If I didn't have a good budget, I think one of the things I would do is this idea of a snackable lunch kind of training where you basically create a manager toolkit, where you basically give them content for 15 minutes to half an hour of their team meeting. We've done ones on anti-corruption where you just want to start a discussion because most really good training is discussion-based, where people can ask questions and learn from each other.

And so toolkits are incredibly cheap to put together. They're essentially a PowerPoint deck. There's some challenges in the execution of making sure you document who attends so your program has that credit. But I think that's one inexpensive way to push things out.

And then I think the other way is just that integration with the rhythm of the business. The less the compliance is a bolt-on and the more it's integrated in what leadership is talking about, you can ride that pretty well. I mean, we have a huge sales meeting every year. Most companies do. We don't want a separate compliance presentation at our annual sales meeting. We want the leadership to be carrying our messages to the sales folks. And so that's what we do there as well. So I think there's a lot of things you can do on a small budget that are very powerful. Yes.

AUDIENCE: You spoke a lot about lessons learned and highlighting use cases or case scenarios of people where they've not behaved well. Something that we're considering is like a university citizenship award, something where we're talking about the behaviors we're aspiring to and showcasing people who are doing some of these behaviors. Have any of you done anything like that, where you're celebrating people who are kind of embodying the code of conduct and doing great deeds, so to speak? And if so, how?

APRIL OLIVER: I can jump in.

SPEAKER 1: Sorry. Can I just repeat that? I'm sorry. I interrupt to say that each time. So the question is the organization has in the past discussed compliance failures as part of its communications. And they're now embarking on a project of communicating about compliance heroes and wondered if you all have had experience with that.

AUDIENCE: And I'd expand it to ethics, not just compliance, but really kind of this is what we're aspiring to. Yeah.

APRIL OLIVER: So our group is the Office of Global Ethics and Integrity. We brand it as ethics from the front end. We may do compliance, but we wanted to have a higher aspiration and really be associated with the best of the best. And I will say compliance and ethics are journeys. And what you can do early on is not what you can do three, four, five years in.

I'm now five years into my journey at Salesforce. Just this past week we launched as a separate office independent of legal, and we did have a branding party in which we created four Ethics Trailblazer awards. And we flew four people in who had been essential to our success, not just in the past year but in all the years of building. We brought a person in who had built a tool for us for free. I mean, when you try to scale and you're small, having the talent that will actually give you something that will give you trackable data-- fantastic. I didn't learn how to do that in law school.

So we gave her one. We gave a person who had someone inside commercial legal. I mean, who doesn't want to leverage commercial legal? Really, that was important to me that we get one person inside that very large, well-funded group that had spoken up and spotted something important, gave her, even though she was on maternity leave. We awarded someone an award to a person inside our public sector, which has its own unique set of compliance risks.

And then all the way around the world. I mean, I think probably any tech company-- APAC is always a high risk region. We rewarded our ER partner out in APAC an Ethics Trailblazer Award. We were really thrilled with the success.

And what we found was that it was strangely emotional for these four people. They hadn't anticipated getting this kind of award or this kind of recognition. And I feel like not only have they given to us and are given back, but going forward that it's not just them, but their entire silos are going to be much more partnered with us going forward.

So really, it cost us nothing except the airplane ticket to get them here for the award, but huge repercussions. I advocate it strongly. Anyone?

SHAWN ROGERS: We use the recognition program that was rolled out by HR. And one of the aspects of that recognition, one of the categories is win with integrity. And so we watch for people who have been given a recognition by a fellow employee around the win with integrity attribute. And we try to data mine that. And if we can find individuals who have made an ethical decision or taken an ethical action when the situation was difficult to do-- in other words, maybe they were facing a certain pressure or strong influence or incentive to do something wrong, but they made the right choice.

If we can find those-- it's very difficult to find people who've done the right thing because it's kind of almost expected to do the right thing-- but when you can find an example, we do like to highlight that either with a recognition award, or perhaps some kind of a spotlight, or maybe a generic article during compliance week or something like that we do like to elevate those who are stellar in doing ethical behaviors.

HERB WILGIS: I think the question of recognition and positive incentives is a really good one, an interesting one. A prior panel touched on this, but it's often hard to find people who want to be in that spotlight. A couple of years ago, I had this great idea. We were going to write a series about all the whistle blowers, people who had come forward and told us about stuff so that we could go fix it. Of course, none of them wanted to be in these articles.

One of the things we've done is a lot of companies like to interview their leaders and like to have their leaders talk about sort of their own journeys. What was their best business decision, what they learned from other companies they worked at, et cetera. And so we seeded some questions about what's been your greatest ethical challenge in your career, and have them reflect on that.

And you find out some really interesting things. We had one leader talk about some of his personal ethical challenges and how he handled those. It really resonated well. So I think seeding those questions in other settings can work well, too.

APRIL OLIVER: So I think we have an online question.

SPEAKER 1: We do. How do you handle code of conducts for suppliers and vendors? Do you use a separate document or incorporate them into your corporate code? So sort of a practical question about supplier codes.

HERB WILGIS: Yeah, we have a separate supplier code of conduct.

SHAWN ROGERS: We do as well. It's based upon our code, but it's written to suppliers and third parties.

APRIL OLIVER: We have a separate one as well. We want to make sure that the employee code of conduct is an employee code of conduct and that they certify to it. And then the supplier chain has sort of different sets of risks and concerns. But they do overlap somewhat.

I'm wondering if I could just-- is there any other question?

SPEAKER 1: Nope, that's all.

APRIL OLIVER: Yeah. So I'm wondering if I could address sort of novel challenges in codes of conduct. I went to a conference recently, too. And I have to call out Unilever for just doing an incredible job on a particular code implementation. At this conference they described the problem of having not all their workforce being literate. And that is an important challenge in rolling out a code of conduct. And it takes a lot of careful thought about how do you educate, how do you signal, how do you communicate if, in this particular instance, there are field workers in Rwanda?

And I'm just going to as best I can, not being part of their program, describe what they showed us, which was they thought about it very carefully. And they went on site and they realized there was this great big tree where the field workers would come take their tea in the afternoon. And by the tree there was a crate where the agricultural equipment had been shipped. And they looked at this, and it was like, a crate is a whiteboard.

And so they developed posters that could be posted on the crate, and they were sort of in sign language, very simplistic, so that they were self-referential through pictures. And so people sipping their tea could look at the crates. Really impressive and creative and thoughtful about the actual employee base.

So in other parts of my life and times of my life we've had to come up with similarly novel ways of, for example, educating factory workers or fulfillment center workers. And you have to really know your employee base before you roll out a plan. I'm sure you have some thoughts on that. Both of you.

HERB WILGIS: Go ahead.

SHAWN ROGERS: Well, yeah. I think every company has a unique set of circumstances that you have to deal with. At GM we have to work across audiences that are very white collar, 65,000 employees that run the administrative side of the business. And then you've got these manufacturing facilities. And the challenges are completely different for those two audiences.

And so rolling out the code and doing the training and the messaging and all that, while you have to cover everybody, you have to be able to cope with strategies that will do that, just like your Unilever example where they did that. We have to go to the factories and say, OK, who's in charge of training? We have to make sure we have the union buy in. And so it's a completely different set of negotiations you have to deal with.

And this is why I think that you get out when people say you need to have a tailored compliance program because every company is going to have a unique set of challenges. And so I'm sure, if you asked somebody from Walmart, they would tell you about completely different approaches they take to reach out to all their employees everywhere.

So again, I think it just a matter if looking at your-- you can't do a cookie cutter program. I guess that's what I'm saying. You have to look at unique situation of every company and come up with a strategy that will take your message all the way to the end of the row. And I think you have to be creative, just like they did with the crates.

HERB WILGIS: Yeah, one hopefully creative approach we're trying right now is our CEO wanted to figure out the question of what makes a good leader because he felt like he understood what a good leader was, but he didn't really understand the data behind what makes a good leader. So he actually hired a group of scientists, neuroscientists, to develop a training for leaders in the company around our leadership principles.

And so we thought about that for ethics and compliance, and we hired the same group of neuroscientists. And we've come up with what we call our Integrity Skills Program-- which we're doing these two-hour sessions with a lot of our country managers and people in the subsidiaries as well as our control functions-- that really tries to answer the question around why do people miss integrity issues, because actually there's stuff in your brain that's working that causes you to not spot issues even if you have plenty of integrity.

So it's really thinking of integrity not so much as a value, which I think everyone thinks they have integrity, but more as a skill, and how do you practice that skill? And that's a really interesting exercise. We're bringing a lot of science and showing people famous videos of experiments. And that's resonated really well. I think training is such a cool field because there's so many different approaches you can try. And I think it's always important to continue to innovate.

APRIL OLIVER: So interesting. Well, I have to be a little bit self-revelatory here and say that I'm married to a neuroscientist, and I'm not sure that's who I would put on my code of conduct training. But I will say that the idea of packaging ethics and compliance training as leadership training, it's really smart and it goes down easier, particularly if you're training people that are brand new to the company. Who doesn't want to be a leader? Who doesn't want to build a brand as a leader?

In some of the training that we do do in the early days at our boot camp, and both for sales and solutions engineers, I or my team partner, actually, with a business leader. And we've tried to not make it just ethics and compliance coming in, but someone who is highly, highly tenured at the company, often someone who's been there 12, 14, 16 years coming in.

And what I typically will do, or my team member will do, is tell the basic policy, the basic rule, the basic code of conduct peace, and then they tell the war stories. And always, always, it brings the house down. And we do make it somewhat competitive. We will put a hypothetical up on the board, and then teams discuss about it at the tables and sort of debate how they would solve it from a leadership perspective. And then we make people stand up and report out from their tables.

And this actually kind of plays into the notion that they're building their brand and they're becoming leaders and they're learning how to lead at Salesforce. And then our final slide is along the lines of we want you to go out and sell. We do want you to sell, obviously. We want our stock to do well, but we want you to do it in the right kind of way. And those are the people that stay at our company over time and are rolled out as leaders.

I mean, they're even putting ethics lawyers into boot camp, which mind you, took a couple years to get. These are things that don't happen instantaneously. You have to build credibility. You have to be making the right calls multiple times along the way before you can really get in the door and build those relationships with folks that are doing this kind of training.

Did either of you do any sort of boot camp early on on the code of conduct with new employees besides the online training?

HERB WILGIS: We have a new employee onboarding program in which they have compliance and ethics training. But we don't do like a boot camp in the way you're talking about.

SHAWN ROGERS: For new executives we do. For anybody that's hired in as an executive, if they get a two-day, deeply immersive curriculum of courses about leadership. But the chief compliance officer or a close delegate will always go in and spend a good hour and a half talking about ethics and integrity at GM, very transparently give the story behind ignition switch and some of the other issues that we've had with the message that we will never forget that. But we're going to move beyond it and become a better company because of that experience.

And so from right off the bat, these new executives get the message that, hey, I'm now part of this company that's being transparent, that's recognized we have issues. We're never going to do it again. We're going to put safety first. And they get a very good message right up front. And I think, going to your point, that does make them feel emboldened and unified onto the message of ethics and compliance and safety and integrity.

APRIL OLIVER: Yeah. And it's so interesting that you talk about senior executives getting the special, smaller, more intimate session. I do think that senior executives sometimes are more hesitant to signal that they might not know an important subject area. And doing that one on one or small group session becomes incredibly important because people can rise up in a silo by being great at sales or great at product development. That doesn't mean that they will know anything about antitrust law.

And it really is important because you can't be everywhere. It's important that those leaders have sort of a basic understanding to be able to pinpoint when there's a violation in their own org because they are really the first line of defense.

Now Rebecca, I'm wondering. You've sat and listened to us. Do you have any questions from your end?

REBECCA: Well, I'm curious about-- first of all, these strategies really are blowing me away. It sounds like you guys are doing some really interesting things. I'm curious about the extent to which you all incorporate, say, social issues that we're hearing about, the MeToo movement, Black Lives Matter, those kinds of issues. Are those things that you're thinking about as you're putting together your training and communications? Do you think it's appropriate for the ethics team to deal with those type of issues? And how do you do so?

APRIL OLIVER: Do you want to go? I'm happy to jump in.

HERB WILGIS: Sure. I mean, I think it depends on how you're structured. For us, know sexual harassment, the training on that is done by HR. But I certainly think, when you think about Black Lives Matter and the MeToo movement, the themes of you know treating people with respect and speaking up when you have concerns are universal.

And so for example, I spend three hours with every new country manager that joins the company. And we talk about cultural issues because the cultural issues they're facing, I learn a lot from that in their particular jurisdictions that they're in. So it's not a subject matter we train on, but I think the themes are applied.

SHAWN ROGERS: I think it's absolutely critical that ethics and compliance have a seat at the table, if not providing leadership, when these kinds of issues come up. When the MeToo movement happened, we had had an anti-harassment training program, and it was out there, had been out there for a while.

But literally on the Friday before the shutdown before Christmas, we were mandated to put anti-harassment into our corporate required training program starting in January. I literally had over the Christmas break to come up with a strategy for that. And it goes back to the partnership. It goes back to the compliance committee we talked about before. You go to these people, you go to your partner in HR and say, what are we going to do to meet this requirement?

And so I got with my HR counterpart, we went to our vendor and said what do you have off the shelf. We said, how can we customize that for GM quickly? We put together a course in a record amount of time. And it turned out to be phenomenally successful. It was the only course in my career that's ever been reviewed and approved and signed off on by the CEO. I've never had a course go to Mary before.

But Mary actually took an active role in looking at that course and saying, you know what? You guys have missed the mark. And she made us go back and make some changes at the very last minute. Instead of rubber stamping it, she made us go back and make changes, which was great because it showed her level of engagement.

But the ethics and compliance team, in partnership with HR and in partnership with senior leadership, had to come together to make that work. And so I don't think a compliance function can say I only own these set of risks. They've got to be looking out at safety. They've got to be looking out at HR issues. They've got to be looking at cybersecurity and coming up with a cohesive approach, what I call capital C compliance. It's not the small C compliance, which is anti-corruption and conflict of interest and code of conduct stuff.

Capital C compliance depends on the company, and that embodies all the risks that could potentially bring the company to its knees, including safety, information security, anti-harassment, and whatever. And it becomes a cohesive effort managed by the top level of leaders rather than just the ethics and compliance function.

APRIL OLIVER: So important. I really do think that our jobs are shifting as the times shift. And what is ethical and what is compliant depends on the breath around us, right?

So yes, in our boot camp I actually did slip in a slide called standards of respect. And it's just common sense. I actually usually get the business leader to speak to that one because I think it's more powerful. And the point is typically guess what, guys? The code of conduct follows you out the doors. It follows you into the bars along Market Street. It follows you to the offsite, wherever you're going. And don't be that guy, don't be that girl who is imbibing too much or whatever and makes the mistake of the callous remark, and then we have an incident.

So the answer is yes, though I do try, for clarity of function, to assign it to the business leader so that they really hear it, absorb it, and understand that it's a value. I will say I've given up my personal time at the table-- I won't go into who or where or what, but with very senior leaders-- to make time for my ER and employment law colleagues because I thought it was important to have them have that audience with senior leaders. It was something I personally advocated for and gave my time because I saw it as part of my ethical responsibility.

A final point I'd like to make on this goes to situations that managers, particularly, may encounter in terms of reporting relationships. Even in our roles, someone may knock on the door and say, hey, I've got a problem. And so what I do try to do when managers are new to the company, I try to give them some kind of a talk track, just to remember in that heat of the moment, it's quarter close, but someone's knocking on your door saying they've got a problem. You need to think very carefully through that moment, because a lot of mistakes can be made at that moment.

You don't want to send the signal of go away, I don't have time for it right now. That would be very bad. The response has always got to be of course, come on in, sit down. Let me see if I can try to help you. If I can't help you, maybe I can direct you to the right person who can help you because typically, in most companies, I think, the ER kinds of concerns are bigger than the bribery types of concern. So you may have someone coming in.

And then I do tell managers listen very carefully, ask the right questions, tell them you will not be retaliated. Make sure that you understand and say that because that is important to signal. And then finally, it's important practically, too, to make sure that they understand that you're not necessarily the decider, that you're just the intake of the alleged facts, and that someone will be getting back in touch with them, whether it's someone from your team or somebody else from a different department.

So just walking people through that talk track, I think, is important for new managers because reports come in at the darndest times. And you need people to be prepared and to respond in a compassionate kind of way when that does happen. How people handle that intake form can really affect risk for the company going forward.

REBECCA: Absolutely.

HERB WILGIS: Just one closing thought from me is don't ignore the data that other control functions have that's relevant for your training program. In other words, some of your control functions like finance, they might have a lot of analytics and data around the control points that they're monitoring.

And those can be very valuable for training because what you want to do with this concept of just in time training that I referenced earlier is deliver a communication and a small bite training to an employee at that moment of decision when they're entering that meeting with a government official, or when they're approving a travel excursion for a government official, or whatever it is.

And you can get really fancy with this and develop very sophisticated analytics and hire data scientists and really start working on the AI. And that's kind of where a lot of companies are going right now. But if you don't have that kind of budget, there is tremendous data available to you already just from the analytics. And getting some of those smart analytics folks to help you target training can be useful.

APRIL OLIVER: You have a final thought?

SHAWN ROGERS: Closing comments. I would say don't get bogged down in just the online training portion of your program. It's easy to do, and it's easy to have that suck all the oxygen out of the room. Make sure you're going to other audiences with maybe more advanced adaptive online training, and then other audiences, including don't neglect your gatekeepers, the people that are going to be your eyes and ears outside of compliance, your finance, your internal audit, your other functions that do investigations.

Make sure they know your rules of the road as well, and help them to become an extended part of your team through your training program. Don't neglect that upper level because that will give you great rewards once you have those eyes and ears looking out for you as well.

APRIL OLIVER: Great. And my final thought is training is a great goal in and of itself, and it's absolutely necessary. But really, it's a cover story for relationship building. So really, as much as you can, you and your people need to get out into the field, no matter how hard it is, because at the end of the day when people have really hard problems and they are scared, they are only going to reach out to someone they know and trust.

And it is unlikely that online training in and of itself will give them the confidence to pick up the phone and call all the way around the world to tell you the bad thing or the bad worry. So you really want to instill confidence. You have to look at it as a long-term relationship. It's not just training in the moment. These are relationships that you're building in each and every site that you go to and each and every country that you visit. Thank you so much.

REBECCA: Thank you. That was so good. Really helpful, and we appreciate you guys being here. Thank you.

So we have a 15-minute break, and then we'll come back here for the final hour of the conference, where we're going to talk about building a culture of ethics, integrity, and compliance at your organization.

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