Empowering Leaders to Build a Culture of Compliance...Empowering Leaders to Build a Culture of...
Transcript of Empowering Leaders to Build a Culture of Compliance...Empowering Leaders to Build a Culture of...
November 14, 2013 Greater Houston Business Ethics Roundtable
Empowering Leaders
to Build a Culture of Compliance
Andrew Baird
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“One thing at GE remains as true today as a hundred years ago: GE’s reputation for unparalleled integrity is its most precious asset.” ~ Jeff Immelt
INTEGRITY: Everyday, Everywhere, Everyone
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Foundation of leadership engagement
Communication
Concern
Reporting
& Resolution
Training
Risk Assessment
& Abatement
Evaluation
Leadership
Engagement
GE Strategy UK Ministry of
Justice
Adequate
Procedures
“Six Principles”: 1. Proportionate Procedures
2. Top-level commitment
3. Risk Assessment
4. Due diligence
5. Communication (including
training)
6. Monitoring and review
http://www.justice.gov.uk/downloads/legisl
ation/bribery-act-2010-guidance.pdf
Leaders
Culture
Drive
Shape
Own
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Risk assessment & Abatement
Communication
Concern
Reporting
& Resolution
Training
Risk Assessment
& Abatement
Evaluation
Leadership
Engagement
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One example of leader engagement The challenge: learning of potential compliance issues and risks in highly distributed workforce
GE Energy businesses:
• Large workforce:
100,000+ employees
• Highly distributed: >80
countries; thousands of
locations, including small
outposts
• Wide range of activities:
line workers in plants,
sales reps and field
engineers traveling the
globe, executives in
offices
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• Every manager in the business
required to meet with direct
reports, review ethics &
compliance policies, and ask for
questions.
• Standardized training materials
available for managers in 13
different languages.
• Questions not answered in the
manager meetings were
escalated and addressed.
Global “Bottoms-Up” Review Annual review with all employees to identify and address ethics & compliance questions and concerns
GE Energy
Bottoms Up Review2010
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Benefits of Bottoms Up Risk Assessment tool Issue resolution: Key Compliance issues have
been identified early and resolved.
Risk assessment: In addition to answering
individual questions, business leaders use the
database to • track trends and identify risk areas, gaps, and needs for process
improvements and training,
• across the business and in specific geographic areas,
demographics, and product lines.
Message to employees: Ensures direct
managers on site set aside time at least once a
year to emphasize importance of ethics &
compliance and open reporting.
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Concern reporting and resolution
Communication
Concern
Reporting
& Resolution
Training
Risk Assessment
& Abatement
Evaluation
Leadership
Engagement
Human Resources
Legal
Manager Complianc
e
Ombuds
Leaders and Open Reporting
Even with a number of ways that employees can raise concerns . . . a large number of concerns are raised to managers
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Open reporting guidance for leaders
Engage: create a safe environment for raising concerns; make time to listen to employees
Evaluate: Assess and categorize concerns
Escalate: Connect quickly with relevant experts
Ensure: Communicate policy of non-retaliation; thank employees who raise concerns
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Training
Communication
Concern
Reporting
& Resolution
Training
Risk Assessment
& Abatement
Evaluation
Leadership
Engagement
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Online Compliance Training
• Core curriculum for all employees
• Leaders can assign courses to their team based on role
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Managers’ Reporting Tools
• Leaders can follow up with employees using on line tools
• Use the tools to understand current status of training goals
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GE /
15 November 2013
Tracking Training Metrics by Leader
Organization/Function
Total
Population Course 1 Course 2 Course 3
P&L 1 1077 97% 99% 100%
P&L 2 448 98% 100% 100%
Function 1 31 97% 100% 100%
Function 2 15 93% 100% 100%
Function 3 7 100% 100% 100%
P&L 3 2429 97% 99% 99%
Function 4 25 96% 100% 100%
P&L 4 2206 97% 99% 99%
P&L 5 607 80% 81% 92%
Total P&L 6855 96% 98% 99%
• Training metrics given to leaders quarterly
• Business and function data provided to all leaders
• Peer comparisons . . . no one wants to be in the red!
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Training Presentations for Leaders
• Training Materials readily available on line
• Training typically done in staff meetings or huddles
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Training Communication
Concern
Reporting
& Resolution
Risk Assessment
& Abatement
Evaluation
Leadership
Engagement
Communication
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Compliance communication tools
• Pre-packaged messages focusing on various topics
• Such as:
− How to Handle an Integrity Concern
− Intellectual Property
− Revenue Recognition
− Doing Business with Gov’ts
− Supplier Relations
− Risks in Emerging Markets
− FCPA
<<Regional leader E-mail Header Here>> • Over the past several months we’ve been looking at Compliance
topics that are critical to the Energy business’ growth and success. • The topics included: • Foreign Corrupt Practices Act (FCPA) • Compliance Risks in Emerging Markets • Intellectual Property Compliance • If you haven’t taken the opportunity to discuss these topics with your
employees yet, I encourage you to do so without delay. • As a manager and leader in our region, you should be the first
person our employees turn to if they have an Integrity or Compliance concern.
• Currently, we will be focusing on Conflicts of Interest. Please click on
the link to access the manager’s package, and spend some time getting familiar with the content. You can use the tools presented in this pitch to help your employees understand what counts as a Conflict of Interest, what the implications are and how to avoid them.
• <<SPACE FOR LOCALIZED REGIONAL MESSAGE>> • If you have any questions about anything in this package, please
don’t hesitate to contact our regional Compliance leader <<INSERT NAME AND E-MAIL ADDRESS>>
• If you would like more information on any Compliance topic at any
time, you can always visit <<Compliance site>> • Always remember to reinforce with your teams, acting with Integrity
and Compliance is everyone’s responsibility, at all times. • Thank you for your support • Best regards, • <<EXECUTIVE NAME AND TITLE>>
• All-employee
communications
• Tailored local events
at sites worldwide
• Posters, banners,
stickers
• Social media
Digital Energy Atlanta team,
In celebration of Spotlight on Integrity Week, you’re invited for candy and conversation with Raquel daFonseca, DE General Counsel, and Courtney McBurney, Energy Management Compliance Officer. Raquel and Courtney will
be available for questions, open dialogue, and to hand out sweet treats to Digital Energy passersby! Raquel and Courtney will be “meet or treating” between 10:00 – 11:30am this Friday, October 26th, in conference room 6-02A-06 (directly outside the 6th floor
elevator bank). Hope to see you there!
Click here to add a reminder to your Outlook Calendar. The appointment will save to your Calendar as “free” time for meeting scheduling purposes.
Tools for site leaders & managers
Local, Business, and Region Approach
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Communication: Recognize & Reward
• Leaders encouraged to reward employees for compliance
• Process varies by GE business
• Peer Nominations through compliance website
• Top-down leadership nominations
• Awards given during high-profile business update
meetings
• Both plaques and monetary awards
• Compliance awards even given to suppliers & customers!
• Leaders measured by awards given in Goals & Objectives
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Evaluation
Communication
Concern
Reporting
& Resolution
Training
Risk Assessment
& Abatement
Evaluation
Leadership
Engagement
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How do leaders evaluate? • Compliance metrics (training, etc.)
• Number of concerns raised by business, region
• Employee opinion surveys
• Attendance and other indications of employee engagement in compliance processes
or
Summary . . .
November 14, 2013 Greater Houston Business Ethics Roundtable
Andrew Baird