finding the right fit: integrating technology to enhance ......6 integrating technology building a...

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Finding the Right Fit:Integrating Technology to Enhance

Your Ethics and Compliance Program and Mitigate Risk

SCCE Compliance and Ethics InstituteChicago, IL

September 17, 2014

Integrating Technology

Who We Are:

• Caroline McMichen, CECO Favorite beer = Blue Moon with an orange

Experience in both E&C and Internal Audit

Technology challenged

• Jennifer Oriel, Global Manager, Training and Communications Midwesterner at heart (go WI Badgers!)

Came up through the HR ranks

We support over 10,000 employees and 12 languages in 15+ countries

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Mexico

Ukraine

Spain

United Kingdom

Miami

Caribbean/C. America

China

Japan

Hong Kong

India

Russia

Central Europe • Bulgaria• Czech• Croatia • Hungary• Montenegro• Romania• Serbia

Denver

Canada

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Extraordinary Brands to Delight the World’s Beer Drinkers

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Integrating TechnologyFinding the Right Fit

In this workshop, we will discuss:

Challenges and opportunities for using technology to enhance ethics and compliance programs and mitigate risk in global organizational settings.

Our journey to leverage technology: real world examples of online solutions designed to engage a global audience, enable meaningful ethics and compliance, and mitigate risk.

Assess your challenges and potential technology solutions.

Integrating TechnologyFinding the Right Fit

Agenda

8:00-8:45 am: Presentation

8:45-9:00 am: Q&As and short break

9:00-9:45 am: Facilitated table exercise

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The Case for Integrating Technology

Most of the “Greatest Barriers to Achieving Program Success*” can be reduced through the leveraging of technology.

* From CELC 2012 State of the Function survey

Integrating TechnologyTrends

In 2012, E&C departments spent roughly

half on technology what they spend on

training and communications.

* From CELC 2012 State of the Function surveys


Technology has historically been used

in the areas of risk assessment, training,

investigations, and policy management

whether purchased or created internally.

* From CELC 2012 State of the Function survey

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GRC solutions - The holy grail for E&C?

• Document compliance controls and activities

• Track completion of training, due diligence and other compliance activities

• Report results of activities to stakeholders

• Assign owners to risk mitigation plans and track progress

• Analyze trends and surface / assess risk areas

• Provide avenues for disclosure and recording of COI and/or G&E

• Manage policy development, maintenance and communication


From the CELC 2014 State of the Function Survey:

• 23% of compliance teams reported they currently use a GRC vendor

• 11% are considering employing a GRC vendor

• For companies without a GRC system, 87% use an in-house developed monitoring tool/system

BUT,

47% of those using a GRC vendor reported spending $300,000 or more to purchase and/or implement the system.

Integrating TechnologyEnhance Your Program and Mitigate Risk

Written Standards

• Interactive Code of Conduct

• Policy Management tools

Training & Communication

• Learning Management Systems

• Communication Portals

• Social Media

Auditing & Monitoring

• Risk Assessment

• Due Diligence

• Disclosure tools (COI, G&E)

• Predictive Monitoring

• Helpline / Case Management

• Surveys

Technology can enhance effectiveness of many program elements:

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Integrating TechnologyChallenges & Opportunities

Many E&C teams, including ours, face:

• Rapid business growth through M&A

• Higher risk profile due to growth in emerging markets

• More complex employee base, i.e. culture, language

• Decentralized IT systems

• IT infrastructure doesn’t keep pace with business growth

• Employees without online access

• Competing business priorities

• Integration efforts slower than ideal

• E&C (and other) resource constraints

• No history of compliance challenges

Integrating TechnologyBuilding a Business Case

Where to Start: Building a Business Case

Pre-work: Program Assessment

Step 1: Identify and Prioritize your risk areas and program gaps

• Where are there opportunities for improvement in program design or effectiveness?

• Are there areas where great effort doesn’t yield great result?

• Where are there existing pain points?


Step 2: Define your goal – to mitigate risk, to improve a process, to communicate better?

“Technology is not a solution, it is an enabler.” (CEB analysis)

• Take the time to understand and document problems and processes before considering your technology options or vendors.

• REALLY understand your needs and objectives: Do you need the Cadillac or a Subaru? Look for a solution that is “fit for purpose” rather than buy in to all the bells and whistles available. It will be a bad investment in a solution that doesn’t meet you needs.

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Step 3: Get stakeholder Input and thus, Buy-In

“Technology investments fail when leadership fails to uncover and articulate true user needs and neglects to include the user in solution design and rollout.” (CEB Legal Realizing Technology’s Productivity Promise.)

• Clearly defined business need

• Executive support

• Enterprise mindset - How else might it be leveraged by the business?

• End-user input


Step 4: Scope your effort

• Does it really belong in E&C? Ownership?

• Do you have the budget?

• Make or buy?

• What resources will be needed?

• What can IT support? Does it fit into overall architecture?

• How will it partner with other, existing systems (HR, Finance, T&E systems, etc.)

• Is there business partner support?

• Realistically, how long will it take to implement?


Step 5: How will you determine success?• Effective rollout support and communication is critical

• User experience dictates technology performance (CEB analysis of 51 system rollouts)

Step 6: Keep an eye on the future• Have we established governance to maintain the integrity of the

system?

• Do we have flexibility to change with the business if necessary?

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Integrating TechnologyOne Example

Our program assessment identified areas of opportunity to make our program more available to our employees (specifically middle managers) and more effective.

Our Challenge - How Can we Better Capture an Employee’s Attention and give them the tools they need?

Our Solution - Create a “home” for E&C that pulls everything together

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Compliance to Culture

• Strategies to Improve

• Create a “home” for E&C that pulls everything together

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Integrating TechnologyOur Company’s Approach

Understanding Our Needs and Objectives

• Program Assessment / Risk Assessment

• Employee Focus Groups

Our Goal:

• To Create a One-Stop Shop of E&C Information and Resources

Selecting the Right Partner

• Creativity

• Cost

• Approach to Design

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Further Refining our Vision in a 3 Day Workshop

• Links to Our Brew

• E&C Branding, Personalization

• Use of Humor

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Does this look like a bribe to you?



• Understanding Employee Needs

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• Understanding Practitioner’s Needs

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• Getting Stakeholder Buy-In

• Design

• Implementation Plan

• Resources

• Building the Content

• Multiple Compliance Topic Areas

• Multiple Languages

• Keeping an Eye on the Future

• What Else Might Make Sense in the Space?

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Launching to Employees with a Communication Plan tied to Our Beer Print Month (Corporate Responsibility)

• Main Intranet Portal Stories and Activities

• Leadership and Team Member Features

• E&C Poll Questions, Yammer posts, local CCTV and other vehicles

• Everything Driving Employees to New Site

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If it doesn’t look right, it probably isn’t.


Measuring Success

• Readership for Speaking Up portal story was above average for the month of September with over 400 readers

• Ethics and Compliance portal launch a success receiving over 700 hits during the week

• Increased number of questions to key contacts listed on E&C site from employees wanting further information on compliance related topics

• Positive feedback from Global Leadership Team and Board of Directors

• Other functional areas wanting help to create a similar site

• 2014 Program Re-Assessment showed significant improvement

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Ongoing Challenges

• Keeping Awareness High

• Keeping Content Fresh with Limited Resources

• Expanding for Acquisitions

• Translations

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Integrating TechnologyOther Examples

Implementing new Learning Management System:

• Significant technical challenges with legacy LMS

• Needed ability to scale delivery, legacy LMS charging on a per-employee basis

• Gained support of business to purchase our own LMS dedicated to compliance training

• Significant RFP process

• Implementation lengthy and challenging

• Ongoing administration a challenge


Online Gift & Entertainment Register

• Primarily used to record gifts & entertainment transparently in compliance with G&E and Anti-corruption policies

• Also used to monitor potential conflicts of interest, i.e. supplier relationships

• Provides another way to measure value for spend

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Our Company’s Approach


Integrating Social Media as an E&C tool

• Using blogs / posts to engage employees

• Monitor culture without squelching the conversation

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Integrating TechnologySuccess?

Significant Improvement in 2014 Program Assessment Results

• Overall score raised a grade level

• Every measure (culture, employee knowledge, compliance environment) showed improvement from prior assessment

So….even if you are not ready for the holy grail (GRC), incremental use of technology to enhance your program is

well worth it!


• Q&A and short break will be followed by a facilitated table exercise


Exercise: Each table will be given an improvement opportunity (with related businesses challenges) for their program and be asked to

• brainstorm potential technology solutions

• build a business case and implementation plan for their chosen solution using tools provided

finding the right fit: integrating technology to enhance ......6 integrating technology building a...

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