Give ‘Em What They - SCCE Official SiteCorporate Compliance Manager Solae, LLC Society of...
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1 An Ethics Program That’s Engaging, Memorable and Fun! Maura I. Brady Cynthia S. Morrison Senior Counsel, Ethics and Compliance J.C. Penney Corporation, Inc. Corporate Compliance Manager Solae, LLC Society of Corporate Compliance & Ethics 2011 Compliance & Ethics Institute • Las Vegas, NV Give ‘Em What They About Our Companies • Founded 109 years ago • One of America’s leading retailers, with over 1,100 department stores (U.S. and Puerto Rico) • jcp.com – one of the largest apparel and home furnishing sites on the internet • Serves more than half of America’s families • 150,000 associates in 22 countries • 18 Supply Chain Centers • Publicly traded (JCP)
Transcript of Give ‘Em What They - SCCE Official SiteCorporate Compliance Manager Solae, LLC Society of...
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An Ethics Program That’s
Engaging, Memorable and Fun!
Maura I. Brady Cynthia S. MorrisonSenior Counsel, Ethics and Compliance
J.C. Penney Corporation, Inc.
Corporate Compliance Manager
Solae, LLC
Society of Corporate Compliance & Ethics
2011 Compliance & Ethics Institute • Las Vegas, NV
Give ‘Em What They
About Our Companies
• Founded 109 years ago
• One of America’s leading retailers, with over 1,100 department stores (U.S. and Puerto Rico)
• jcp.com – one of the largest apparel and home furnishing sites on the internet
• Serves more than half of America’s families
• 150,000 associates in 22 countries
• 18 Supply Chain Centers
• Publicly traded (JCP)
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About Our Companies
• Founded in 2003 as a joint venture between DuPont and Bunge
• World leader in developing innovative soy technologies
• Global company headquartered in St. Louis, MO with regional operations in Asia Pacific, Europe and Latin America
• Serve more than 3,000 customers in more than 80 countries
• 2,400 employees worldwide
Where we Started
• Tradition of Integrity
• Hotline
• No Dedicated Ethics
and Compliance Staff
• Identity Crisis
• Duplicate Policies
• No formal Compliance
Program or Staff
August 2009 Who is Solae?
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Our Common Challenges
• Diverse workforce
• Employee turnover
• Multiple locations
• Multiple languages
• This is so boring!
The truth hurts sometimes but it can also set you free, Make a list of the challenges in your organization. Be prepared to be brutally honest and ask others for feedback too. You have to know what the problem is before you can solve it.
From Our Notebook:
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Making Lemonade
• Effective Compliance Programs in
Place Including:– Code of Conduct and supporting policies
and procedures
– High-level oversight
– Care in delegation
– Education, training and communications
– Annual business ethics certification
– Periodic risk assessments
Making Lemonade
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What’s Our Solution?
Make it a custom fit!
Big Idea #2
Getting Creative
• Enlist the help of creative people inside
and outside of your organization
• Reevaluate everything: format, tone,
frequency, content
• Consider branding your program. If you
have a brand that works, stick to it.
• Edit, edit, edit. Be brave and toss out what
doesn’t work.
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Hosted by the
Ethics and Compliance Group
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Shhh!
Statement
of Business
Ethics
@Doh!Who You
Gonna Call?
Wine Me,
Dine Me…
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Solae’s Core Values are the foundation of who we are:
Getting Creative
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Credit Card Shuffle
(Gifts, Entertainment & Travel)
Getting Creative
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Take it one step at a time and focus on progress not perfection. Freshen up your Code of Conduct or change the way you present an existing live training program. Roll out just one new piece & gather feedback from stakeholders. Keep moving and use what you learn in the next project.
From Our Notebook:
Making a Custom Fit
• Why is customization so important ?– Audience feels more invested in the message. You
know who they are and you’re speaking right to
them.
– The message doesn’t get lost in the clutter. If only
some of what you send out applies to me, I’m more
likely to tune out – even when I really need to tune
in.
– Demonstrates that the Ethics and Compliance
function knows the company too. They’re one of
us.
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It’s important to
start with “Why?”
Customizing Training to Fit the Audience
Making a Custom Fit
• If you can, start from scratch.
• Or, take an out-of-the-box program and
make it your own.
• Use what you’ve got. Leverage internal
resources–training, public relations,
marketing, operations or any other
functional department that can add
value.
• Create ownership and accountability
opportunities.
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Keeping it relevant
• Creativity helps keep the audience’s attention
and customization helps build their
understanding of the message. But that
understanding can fade.
• To build or maintain an ethical culture,
organizations need to keep the message alive
all year long.
• Turn your communications into an ongoing
dialogue.
• Communicate, communicate, communicate…
using different mediums.
Keeping it relevant
• Ethics Month
• Core Values and Global Core Values Award
• Targeted Brown Bag Training
• On-Boarding Materials for New Hires
• Refreshed Hotline Posters
• Get on the Agenda for Company, Department or
Staff Meetings or Supplier/Vendor Summits
• Ethics Alerts/Bulletins and Desk Drops
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Break it up! Can you get across the same message in a series of short bursts instead of one long session? Create case studies or thought starters for managers to use during the first few minutes of staff meetings. Email a short but highly relevant ethicsfact each month
From Our Notebook:
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Maura I. Brady Cynthia S. MorrisonSenior Counsel, Ethics and Compliance
J.C. Penney Corporation, Inc.
Corporate Compliance Manager
Solae, LLC
Society of Corporate Compliance & Ethics
2011 Compliance & Ethics Institute • Las Vegas, NV
Questions?
