Corporate Integrity Services - EY · PDF fileTraining and education ... • Advised a...

Corporate Integrity ServicesIntroduction

Global organizations have realized that the ethical way of doing business is not just an option but the only one for sustainable growth. Embedding ethics in business from strategy to operations is a global leading practice. There is a clear move toward “ethics” from “compliance,” the latter being a subset of the former.

The rise in misconduct, financial and accounting fraud and corruption cases has necessitated stronger enforcement by regulatory authorities and has led to companies’ integrity and risk controls coming under the scanner. Today, voluntary initiatives in doing business ethically are the preferred mode.

Organizations need to design and implement effective and integrated ethical frameworks to be able to run their business in an ethical manner. The ethical framework needs to be fully embedded into all levels of an organization to meet its primary objectives of doing business, while taking into consideration the interests of all stakeholders including:

• Society

• Government

• Customers

• Employees

• Competitors

EY’s ethical framework is depicted below:

CULTURE

Mission

Valu

es

Business Strategies Tone from Top

Code of Conduct

Vision

Ethics requirementsMandatory Voluntary

Legal/ Regulatory Business

Ethics Program

Effective Integrated

Keep us out of trouble Make our business betterPrevent and detect

non-complianceEnhance business performance

drive competitive advantage

Alligned and co-ordinated compliance risk management activities

People Process

Corporate Governance and Oversight

Strategy and support functions

Compliance Risk Management Functions

Operations and business units

Ethics functions

Individual employees

Organizational charter

Organizational structure

Resources and accountabilities

Company development

Strategic planning

Risk assessment

Controls, policies & procedures

Training and education

Preparedness and practice

Monitoring and evaluation

Incident response

Communications and reporting

Information & technology

Measures and Metrics

Information management

Performance reporting

Decision support

Once established, a sustainable ethics framework needs to evolve over time and revisited and reviewed for changes in the business environment, including laws

and regulations, and also incorporate feedback received from stakeholders.

Given below, is the required chain of continuous improvement that begins with the foundational component of risk assessment.

Learning from events

Provide training

Risk assessment

Code of conductM

onito

ring

Non-complian

ce eve

nts

Provide further training Emplo

yee f

eedb

ack

Publicize expected employee behavior around the most significant ethical risks identified through a ethical risk assessment

Identify employees to be trained on key policies, and conduct training and tests for comprehension

Continuouslyimproveprogramsbylearning from incidents of non-compliance as input to update

policies and training material, as well as a key input to the next compliance

risk assessment

Provide the leadership team with a data-driven

understanding of performance against key

compliance objectives

Gather feedback on training to improve the quality and effectiveness of the program

Contact us

Arpinder Singh Partner and Head - India and Emerging Markets + 91 124 443 0330 [email protected]

Jagdeep Singh Partner + 91 80 6727 5300 [email protected]

Rupen Nisar Director + 91 20 6603 6260 [email protected]

Prakash Kamath Director + 91 22 6192 1408 [email protected]

How EY can helpOurprofessionalsfromtheCorporateIntegrityteamhavewideexperience and can help you in all the facets of implementing an ethical framework — from assessment of ethical risk to creation of policies and assistance in establishing an ethicsdepartmentatagrouporcompanylevel.Theleafletsaccompanying this write-up provide the details of our solutions on corporate integrity.

Our select credentials

Settingupanethicsfunction• Advised one of the largest business groups in the country

insettingupitsEthicsDepartment,includingjobprofiles,SOPs,methodologyforethicsriskassessment,periodicassessment of ethics functions, training & awareness and investigations

• AdvisedaDelhibaseddiversifiedgroupinenhancingtheirethics & corporate governance functions, including role of group ethics committee, fraud response plan, training & awareness

Prevention of sexual harassment at the workplace• HelpedtocreateaPreventionofSexualHarassment

framework, along with a response plan, and conducted internaltrainingformembersoftheInternalComplaintsCommittee(ICC)andseniormanagementofoneoftheleading manufacturers of industrial products in India

• ConductedtrainingformembersoftheInternalComplaintsCommittee(ICC)andseniormanagementofaleading global liquor company

Whistle-blowing services• Reviewed and developed the whistle blowing mechanism

ofaleadingautofinancecompany.Thisincludedreviewof existing whistle-blowing policy, developing a fraud response plan, conducting training for senior management and other employees, and implementation of the channels through a third party service provider

• Assisted a BPO in implementing their whistle-blowing mechanism. This included developing their whistle-blowing policy, developing complaint response plan, developing contentfortraining(facetofaceandwebbased)andconducting training of senior management. We also advised their IT team in developing the whistle-blowing channels(hotline,websiteandemail)

Codeofconduct• Build and implemented a roll out plan for the code of

conduct to all employees which included developing content for relevant trainings, train the trainer workshops. Also assisted the client in creating web based learning modules

• Conductedareviewoftheexistingcodeofconductandrecommended changes to it. Additionally assist the client in strategizing and rolling out awareness workshops of the policies.

Corporatelearninganddevelopment• Developed and conducted trainings on risk assessment

and various related control measures for a telecom infrastructure company. The trainings including exercises and interactive sessions, concept of delivery, training the trainers. Also assisting the client in developing web based learning modules.

• TrainedemployeesofamediacompanyonFCPAguidelines, bribery and corruption risks

Corporate Integrity ServicesSetting up an ethics function

It is imperative for large business groups to set up ethics functions at the group level, while supplementing it with similar functions at the entity level to have a common philosophy, policies, procedures, methodology and operations with regard to ethics.

Settingupofanethicsfunctionatthegrouporcompanyleveldoes not only involve conceptual thinking and formulation ofguidelines,butalsoappropriatestaffingandre-alignmentof reporting relationships — especially between group-level functionaries and those at the entity level.

A robust ethics function comprises of three elements — develop, sustain and respond. An ethics department should develop and sustain an ethical culture in an organization and respond to any instances of ethical violations, as depicted alongside:

How EY can help

Develop Sustain Respond

Policies• Author

• Formulate

• Amend

• Benchmark

• Synchronizewithotherpolicies—anti-fraud,CSR,safety,etc.

• Continuouslyimprove

• Assess ethics risk

Ethical Assessment• Conductindependentassessment

• Conductperiodicassessment

• Coverallunits,functions,businesses and operations

• Review and report

• Incorporate remediation in functions — the way forward

Fraud response plan• Centralresponseteam

• Cross-functionalcommitteesandsubcommittees

• Categorization/Prioritization

• Escalation and investigation protocol

• Discipline and enforcement of compliance

• Controlremediation

• Legal action

Reporting

• Internal reporting

• Reportingtoboard/auditcommittee

• Reportingtoregulatory/enforcement agencies

Declaration process• Periodic

• Comprehensive

• Action-oriented

• Remediated

Whistle-blowing mechanism• Robust

• Coveringallstakeholders

• Anonymity

• Outsourced

• Multiple channels

• Cross-functionalteams

Training and awareness• Strategize

• Roll out plan

• Develop content

• Train the trainers

• Conductface-to-facetraining

• Encourage web-based learning

• Identify ethics champions across locations

Ethics helpline• Different from whistle-blowing line

• May be run internally or outsourced



Prakash Kamath Director + 91 22 6192 1408 [email protected]

Contact us

Our credentials

• Advised one of the largest business groups in the country in the enhancement of their Group ethics function, suggested relevantprofiles,modelpoliciesandprocedures,methodologyfor ethics risk assessment, periodic assessment of ethics functions, training & awareness and investigations

• Assisted one of the largest business groups in the roll out of an annual compliance assessment for group companies after the review of submissions by group companies and inclusion of additional parameters

• Advisedadiversifiedgroupinenhancingtheirethics&corporate governance functions, including role of group ethics committee, fraud response plan and training & awareness

• Advised a leading media and entertainment company in the assessment of their existing ethics function and policies. Subsequenttotheassessmentpoliciesandprocedureswere developed or enhanced as required, we developed new training content and conducted trainings and set up a new whistle blowing mechanism, and created a cadre of “Ethics champions” to address employee queries.

How EY can helpEY can help you to effectively set up and manage all the three functions, as detailed below:

• Develop

• Definingrolesofvariouspositions(ethics)atthegroupandentitylevels(andreportingrelationships)

• Definingframeworkforassessmentofethicalrisk

• Helpinginandadvisingondefiningpolicies

• Training and awareness – strategy, content, delivery and measurement of effectiveness

• Sustain

• Framework and methodology for periodic assessment studies and benchmarking

• Protocolsforfollow-upactioninlightoffindingsofvarious studies

• Periodic review of whistle-blowing or ethics hotline

• Respond

• Settingupofresponseunitatgrouporheadofficelevel—roles,establishmentofprotocols,structured criteria for central response team to intervene, oversee or advise

• Formulating methodology for investigations and proactive/reactiveinterventions

• Providingadviceonstaffingofdepartments

Corporate Integrity ServicesCode of Conduct

OneofthemainpillarsoftheethicalenvironmentinanorganizationisaneffectiveCodeofConduct(CoC)thatdetailsanticipatedconductatwork.

ACoCmusthaveguidelinesforbehaviorexpectedfromallwhomitappliesto,toreflectaccuratelythe values and philosophy of a company. It covers aspects related to key drivers of acceptable conduct vis-à-vis compliance, good governance and protection of reputation. This effort is, however, incomplete without an effective roll out plan for awareness across levels.

More often than not, companies develop the documents, but struggle with its communication and in creating awareness of their value.

ConcernsoverthegrowingnumberofcorporatescandalsandtheirimpactonthereputationoforganizationshaveemphasizedthegreaterneedofaneffectiveandwellcommunicatedCoC.

What does the CoC do?• Bringstogetherthemostimportantpoliciesandrulesandaimstomaintainalawful,honestand

ethical work environment in an entity

• Defineswhatanentityexpectsfromitsemployeesandotherstakeholders

• Enables employees to work in a manner that is consistent with the entity’s values

• Guides employees on making ethical decisions so that an entity is able to uphold and maintain its values and protect its reputation

• Servesasadirectivecontrolthatcomes before preventive and detective controls

Drivers of a CoC• The contents of a CoC are driven by the values of the organization and other factors. Below are

some indicative factors as set out below:

Government and regulations Work culture Business transactions

and interactionFinancial reporting

and asset protection

• Compliance-relatedrequirements

• Bribery and corruption laws

• Laws for fair competition

• Political and religiousaffiliation

• Practices relating to diversity and inclusion

• Harassment at the workplace

• Sexualharassment

• Environmental safety

• Whistle-blowing andreporting(vigilmechanism)

• CorporateSocialResponsibility

• Gifts and business courtesies

• Conflictofinterest

• Confidentialityandintellectual property

• Media and communications

• Off-duty conduct

• Duties toward customers

• Protection of assetsandfinancialreporting

• Insider trading

Communication and AwarenessAsmentionedearlier,communicationandawarenessofaCoCiscriticalinachievingthedesiredlevelof ethical environment in an organization. More often, we see companies failing to do a good job of this, partly because they take it ‘lightly’, and partly because they are not aware of leading practices. A well thought of roll out plan for training and robust awareness programs are critical components for developing and sustaining the ethical environment.

How EY can helpAtEY,wehelpcompaniesindevelopingaCoCorreviewing and revising existing ones. We also help themtodefineandimplementawell-structuredapproach to create awareness across all levels.

• Assessment

• ReviewingexistingCoCandstudyingcurrent environment

• Identifying any apparent inconsistencies within provisions or with other related policies and relevant regulatory guidelines

• Implementation

• Collectively working with stakeholders to ensure a tailor-made dissemination strategy

• Creatingcontentforfacilitator-ledtrainingand self-web-based learning with relevant case studies

• Building capability to drive such initiatives independently through leadership and conducting train the trainer sessions

• SettingupanannualdeclarationprocesstoreinforcetheimportanceoftheCoCand the expectations from employees

• Review

• Periodically reviewing adherence through a monitoring mechanism for inputs for revision of content or process for communication and awareness if required




• Build and implemented a roll out plan for the code of conduct to all employees which included developing content for relevant trainings, train the trainer workshops. Also assisted the client in creating web based learning modules.

• Conductedareviewoftheexistingcodeofconductandrecommendedchangestoit.Additionallyassistedtheclientinstrategizing and rolling out awareness workshops of the policies.

Our credentials

Doesyourcompanyhaveaguide/reference for employees to support their day-to-day decision-making, especially in ethical dilemmas?

Do you have a common framework and rules on how employees should do their work to positively affect the company’s vision?

How do you protect yourself when an employee’s actions can expose you to legal risks?

AreyousurethatyourCoCandotherpolicies are in line with the laws of the land and international best practices?

Contact us

Awareness Well prepared Requires consideration

Are your employees aware of the organizational values and behavior expected of them?

Are they sure of the details of the ethical standards you strive to maintain within your company?

Do your employees know how much and in what ways their misconduct or violation can cost the company?

Are your employees aware of the laws that apply to them in their scope of work and how important it is to comply with these?

Do your employees know how they can support you by maintaining an ethical environment in your organization by reporting wrongdoings through appropriate channels?

Questions for consideration

Corporate Integrity ServicesPrevention of sexual harassment

With the business environment moving toward a global platform, organizations with gender diversity are growing at a rapid rate. Gender diversity is vital foranyorganization.Studieshaveproventhatan organization with a demographically diverse workforce sees improvements in its financial performance. One of the key focus areas for India Inc. is to protect the interest of the increasing number of women joining the workplace and ensure a safe and secure working environment for them.

Most organizations may have put in place policies under the relevant provisions of the Vishakha guidelines in their endeavor to curb instances of sexual harassment at the workplace. However, they need to revisit their internal policies to keep pace with the changing regulatory scenario. The institutionalizationoftheSexualHarassmentofWomenatWorkplace(Prevention,ProhibitionandRedressal)Act2013(referredtoastheAct),whichreceived the President’s assent in April 2013 and was further notified in December 2013, is a landmark actiontakenbytheIndianParliament.TheCriminalLaw Amendment 2013 related to sections 354A, 354B,354Cand354DoftheIndianPenalCodesupports the act.

Salient features of the Act The Act aims to provide women protection against sexual harassment at their workplace as well as drive prevention and redressal of complaints of sexual harassment. The provisions of the Act aim to protect the interest of women employees and fuel adoption of good governance practices in organizations.

Key compliance requirements for employers: • Provide a safe working environment

• Constitute Internal Complaints Committee (ICC)

• Organize orientation programs for members of ICC

• Publicize penal consequences of sexual harassment at a conspicuous place in the workplace

• Organize regular awareness programs for employees on the Act

• Set up grievance redressal mechanism for women employees to voice their concerns about possible instances of harassment

• Monitor timely submission of reports by the ICC on complaints. Take action against complaint within 60 days of the report date.

How EY can helpWe help companies formulate their prevention of sexual harassment policies and develop response plans. We also review and enhance their existing policies to ensure that these are compliant with the Act. In addition, we help them formulate and conduct awareness programs and workshops through face-to-face or web-based training.

EY’s solution Our help

Settingupofpreventionofsexualharassment framework

• Review or revise existing policy

• IncludespecificexamplesandFAQsrelatedtonatureoftheindustry/business

• Createresponseplanforincidences

• HelpinsettingupofICCormanagementofexistingcommittee

• Provide consultation on structure for committee

• Outline redressal process, awareness plan, etc.

Training and awareness program for different stakeholders

• Training for ICC:

• Introduction to the Act

• ICCmembers’rolesandresponsibilities

• Legal aspects and procedures

• Guidance on appropriate action

• Investigative interviewing skills

• Reporting and communication guidelines

• Training for leadership team:

• Definitionofsexualharassmentwithexamples

• Their roles and responsibilities

• Overview of complaint process

• Legal aspects and procedures

• Training for employees:

• Awareness and sensitization training programs

• Train the trainer sessions

• Web-based training

Gap analysis and reactive services • If there is an existing policy, identify gaps according to the mandates in the Act and recommend best practices

• Resolve queries

• ConductinvestigationsaccordingtotheguidelinesoftheActandprinciplesofnaturaljusticeinthecaseofacomplaint/incidence

You already have a gender neutral policy. Do you need to draft a new policy specifically for your women employees?

If a contractor working at your premises alleged sexual harassment, is that your responsibility?

What do you do if a woman employee does not report an incidenttotheICC?

If you already have a whistle- blowing hotline, does an employeestillneedtoapproachanICC?

If a woman employee is subjected to sexual harassment while traveling to the company’s overseas location, is this covered under the Act in India?

If an act has occurred during official travel, does it constitute sexual harassment?

What are considerations for deducting “compensation?”


Do you need to constitute an internal complaints committee at your office?

For a complaint made before 9 December 2013, would you refer to the old guidelines or the new Act?

Whoisdefinedasan“employer”?IsittheCEOortheBoard of Directors?

Whatisconsideredasunwelcomesexualconduct?Candiscrimination be termed sexual harassment?

Whatis“quidproquo”sexualharassment?Canasexualharassment claim be made by an employee even if the person consented to the sexual activity?

Are all employee aware of the internal complaints committee?

Our credentials

• HelpedtocreateaPreventionofSexualHarassmentframework,alongwitharesponseplan,andconducted internaltrainingformembersoftheICCandseniormanagementofoneoftheleadingmanufacturersofindustrialproducts in India

• ConductedtrainingsformembersoftheICCandseniormanagementofaleadinggloballiquorcompany

• Outlined a PreventionofSexualHarassment policy with FAQs, response plans and guidelines on compliant handling processesforatextilemanufacturingcompany.AlsoassistedthemanagementinsettinguptheICCandtrainedthecommittee members and employees on this subject

• CreatedaPoSHresponseplan,includingrolesandresponsibilitiesofICCandmanagementandconductedtrainingsfor them with case studies based discussions



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Corporate Integrity ServicesWhistle-blowing services

TheCompaniesAct,2013hasbeenamajordriverofchangeintermsofcomplianceandcorporategovernance.OneofthekeyprovisionsoftheAct(readalongwithrules)mandates every listed company and certain other classes of companies to establish a vigilmechanism(whistle-blowermechanism)foritsdirectorsandemployeestoreportgenuineconcernsintheprescribedmanner.TherevisedCorporateGovernancenormsoftheSecuritiesExchangeBoardofIndia(SEBI)havealsomadeimplementationofwhistle-blower mechanism mandatory for listed companies.

A whistle-blowing mechanism not only helps to detect fraud in organizations, but is also used as a corporate governance tool that prevents and deters fraudulent activity. Many companies have whistle-blowing policies. However, these are not backed by an adequate framework to make it an effective tool in detecting and preventing fraud or misconduct.

Provisions relating to a vigil mechanism in the Companies Act, 2013

Sec 177 (9) - Establishment of “vigil mechanism”Every listed company, or such class or classes of companies, as may be prescribed, is to establish a vigil mechanism for directors and employees to report genuine concerns in such manner as may be prescribed.

Sec 177 (10) - Safeguards against victimization

• Policyagainstvictimizationofpersonsusingthemechanism

• Provisionforaccesstochairpersonofauditcommitteeinappropriateorexceptional cases

• Display of policy on company website

• Inclusion of “vigil mechanism” in board’s report

Schedule IV - Code for independent directors

• Ascertain and ensure that company has an adequate and functional mechanism

• Ensure that the interests of individuals who use the mechanism are not prejudicially affected

The act also requires the auditors to report frauds that they come across in the courseoftheirwork,totheCentralGovernment.However,intheguidancenotefromICAIonFraudreporting,ithasbeenclarifiedthatincaseafraudhasbeenreportedthrough the company’s vigil mechanism and has been remediated by the management and informed to the auditor, then he will not be required to report the same. Thus existenceofwhistle-blowingmechanismactsasa“SafetyNet”forthemanagement.

We help organizations develop or review whistle-blowing policies and related procedures. We also help them effectively address complaints by formulating response plan. In addition, we provide them assistance in conducting training and awareness sessions for their employees and other stakeholders.

• Establishing a whistle-blowing mechanism

• Review or develop whistle-blower policy

• Advise on selection of whistle-blowing channels

• Help in implementation of mechanism (throughathirdpartyorclient’steam)

• Help in development of a fraud response plan

• Provide assistance on constituting cross-functional committee

• Reviewing complaints and recommending response

• Provide advice with regard to action to be taken on complaints received

• Help organizations conduct investigations

• Training and awareness sessions

• Assist in strategizing training

• Develop content for training — face to face and web-based

• Help organizations conduct training

• Diagnostic reviews

• Understanding and reviewing existing policy, procedures and mechanism

• Advising on areas of improvements


AreweincompliancewiththeCompaniesAct/CorporateGovernancenorms?

Have we offered the right set of channels for reporting?

Shouldweallowanonymity?

Shouldthemechanismbeoutsourcedtoathird party?

Have we created adequate awareness about the mechanism?

Do we have guidelines for action to be taken on complaints received?

Is an appropriate team of individuals handling complaints received?

Do we have a database of complaints received, action taken and relevant documentation?

Contact us





Our credentials• Reviewed and developed the whistle blowing mechanism of a leading auto finance company. This included review

of existing whistle-blowing policy, developing a fraud response plan, conducting training for senior management and other employees, and implementation of the channels through a third party service provider

• Assisted a BPO in implementing their whistle-blowing mechanism. This included developing their whistle-blowing policy, complaintresponseplan,contentfortraining(facetofaceandwebbased)andconductingtrainingofthesenior managementgroup.AlsoadvisedtheITteamindevelopingthewhistle-blowingchannels(hotline,websiteandemail)

• Assisted a company from the media and entertainment sector in reviewing their whistle-blowing policy, developing a fraud response plan and implementing the channels along with a third party service provider

• Assisted in implementation of whistle-blowing channels along with a third party service provider for a leading pharmaceutical company

• Assisted in reviewing the whistle-blowing policy of a consumer electronic manufacturer taking into consideration provisionsofCompaniesAct2013andleadingpractices

Corporate Integrity ServicesCorporate learning and development

In recent years, where corporate scandals and breaches of ethical guidelines have rocked boats globally, companies are constantly seeking ways to prevent non-compliance, to protect their reputation and to limit the liability on their management and supervisory bodies, and their employees.

To achieve sustainable compliance, organizations not only need to design and implement effective and integrated compliance solutions, they also need to work towards increased awareness of employees of ethical practices, applicable laws and possible consequences of violations.

At the same time, it is also important to focus on practical application and learner engagement for effective dissemination of learning and maximum retention in the process of knowledge transfer.

Our team at EY strives to achieve these objectives by maintaining the right balance and enhancing interactivity in delivery through case studies and scenarios, which are relevant to the industry, employee roles and the cultural context.

• Codeofconduct

• Whistle-blowing policy

• Policy for prevention of sexual harassment

• Anti-bribery and anti-corruption policy

• Training on fraud, investigation and ethics

How EY can helpWe help organizations to strategize the roll out of awareness training programs to their employees and business partners and deliver training.

The details below explain EY’s approach to conceptualization, development of training content and its delivery:

< <<

Considerations for strategyA structured approach to identificationandcategorizationof the target audience (employees,businesspartners/their employees or contracted workers),basedonthefollowing(illustrative)toachievemaximumcoverage:

• Level in organization and role

• Interaction with third parties

• Level of Intellectual Property or access to sensitive information

• Knowledge of languages

• Computerliteracy

• Location

Deliverables• Roll out plan detailing:

• Numberoftrainingsessions

• Timelines/Faculty

• Modeoftraining(facetofaceorweb-based)

• Languageofdelivery

• Annual declaration process

• Screen-savers,posters/otherawareness methods

Considerations for content development:• Keyareasoffocus(may

differ for each category of participants)

• Practicalillustrations(basedoncasesorsituationsspecifictoacompany)

• Attention span of category of audience

• Mode of presentation

• Testing audience’s comprehension

Deliverables• Contentforface-to-face

trainingforvariousclass/levelof audience

• SCORM/AICC/TINCancompliant content for web-based training for hosting on LMS

• Questionnairestobeusedforweb-based training

• Speakers’notesandinstructionsfortrainers/facilitators

• Logisticalrequirements

• Contentforannualdeclarationform

Considerations for dissemination:• Timelinesavailable

• Logistics

• Targetaudience

• Engagementandexplanation

• Learning/Feedbackfromprevious training

Considerations for other awareness material:• Placement of posters, mailers,

etc.

• Wall-papers and screen-savers on computer

• Other awareness material and initiatives

Deliverables• Delivery of training

• Feedback forms

• Test questionnaires

Stra

tegy

Delivery

Content development

EYApproach

Our credentials• TrainedallemployeesofleadingmediacompanyonFCPAguidelines,briberyandcorruptionrisks

• TrainedfunctionalheadsofanautocomponentsmanufacturerandpapermanufacturingcompanyonFCPAawareness,bribery and corruption risks

• ConductedatrainingsessionfordepartmentheadsofalargesoftwarecompanyonFCPAguidelinesandrelatedleadingpractices

• Developed and conducted trainings on risk assessment and control measures for a telecom infrastructure company. These trainings include exercises and interactive sessions, concept of delivery, training the trainers and developing web based learning modules.

Types of training

Senior management Employees

Vendors/ Third

parties

Internal complaints committee

Internal Audit/Investigators

Prevention ofSexualHarassment (PoSH)

Legal statutory requirement

Legal statutory requirement Awareness Skill

CodeofConduct(COC)

Awareness* Awareness AwarenessEnhancement/Legal statutory

requirementAwareness

Whistle-blowing(WB)

Awareness* Awareness* Awareness* Awareness

Anti-Bribery & Anti-Corruption(ABAC)

Awareness Awareness Awareness SkillEnhancement

Investigation Skillenhancement Awareness Awareness SkillEnhancement

Fraud prevention

Awareness* Awareness* SkillEnhancement

Ethics dilemma workshop

Awareness Awareness Awareness

* Legal statutory requirement in some cases

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The table below details areas of training on corporate governance offered by EY:

Corporate Integrity Services - EY · PDF fileTraining and education ... • Advised a...

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