May 8th 3 45 pm maximizing integrity at key career moments
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May 8th 3 45 pm maximizing integrity at key career moments May 8th 3 45 pm maximizing integrity at key career moments Presentation Transcript

  • Why Career Moments Matter...And What You Can Do About ThemCEB Compliance and Ethics Leadership Council
  •  2© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNACCELERATION OF CORPORATE CHANGEMacroeconomic, market,and business uncertaintydrive frequent changesto corporate strategy,financing, and operatingprocesses.■■ In the past two years,84% of companiesexperienced a significantcompany-wide change.n = 63.Key Trends Driving Corporate ChangeCompanies Experiencing Change in the Past Two YearsCommunications Executive Council Member Survey, 2012Single Company-Wide Change0%35%70%0%6%10%19%65%NoChangeMinorChangeIsolatedChange in BUMultiple Company-Wide ChangeMacroeconomic Changes■■ Slow, volatile economic growth■■ Uncertain interest rates■■ High unemployment ratesMarket Changes■■ Increase in global regulationsand uncertainty in enforcement■■ Advance in technology■■ Shift in consumer demandProduction Changes■■ Increase in supply chain risks■■ Shift in employeedemographics, geography,and expectations
  •  3© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNEMPLOYEES FEEL THE PAIN Percentage of Employees Experiencing Given Career Moment in the Past YearSelect Employee Moments , CELC Survey Data 2012Corporate changesmanifest as careermoments for employees.■■ Eighty-three percentof employees haveexperienced careermoments in the past year.■■ On average, employeesexperience 2.2 careermoments per year.n = 3,311.Degree of Change FatigueCompany Reported, CEC Member Survey 2011n = 63.0%25%50%2% 3%10%24%44%14%3%Not at All Very Low Low Moderate High Very High SevereFrequencyofResponseIncreasing StressSixty-two percent of corporateemployees agree that workplacestress has increased in the pasttwo years.LayoffsofTeamMembersSignificantOrganizationalRestructuringSubstantialChangein SeniorLeadershipChangeinYourDirectManagerHiringFreezeSignificantChangein JobResponsibilitiesWageFreezeorSalaryCapReductioninBenefitsTransfertoNewTeamReductionorEliminationinVariablePaySignificantChangeintheSkillsYouUseEarlyRetirementOfferMerger/AcquisitionMandatoryUnpaidLeave/FurloughPromotiontoManager0%25%50%23% 21% 20% 18% 17% 15% 14% 13%10% 9% 8% 7% 5% 5% 4%
  •  4© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNA SCIENTIFIC APPROACHCELC’s Workforce Change Survey, 2012The CELC launcheda new-to-world surveyto understand theimpact of careermoments on employeebehaviors, perceptions,and receptivity to trainingand communications.■■ The CELC exploredthe relationship betweenspecific career momentsand the related corporateand compliance response.What Impact Do CareerMoments Have on EmployeeBehavior?Which Career MomentsDo Employees Experience?How Can Compliance andEthics Maximize IntegrityDuring Times of Change?Impact■■ Observations of Misconduct■■ Misconduct Reporting Rate■■ Perceptions of Integrity■■ Employee Engagementand Discretionary EffortCareer Moments■■ Corporate Change 1■■ Compensation/BenefitChange 2■■ Role and Team Change 3■■ Promotions 4Intervention■■ Timing of Intervention■■ Channel of Intervention■■ Content of InterventionEmployee Demographics■■ 3,311 responses from full-time employees of largeorganizations (500+employees)■■ 25+ countries represented■■ Respondents representfull range of industriesand corporate positions■■ Average respondent ageof 37.41 Corporate Change: Layoffs of team members, significant organizational restructuring, merger/acquisition,and/or substantial change in senior leadership.2 Compensation/Benefit Changes: Wage freeze or salary cap, reduction in benefits, reduction or eliminationin variable pay, mandatory unpaid leave/furlough, hiring freeze, and/or early retirement offer.3 Role and Team Change: Significant change in job responsibilities, significant change in skills you use,change in your direct manager, and/or transfer to new team.4 Promotions: Promotion to manager and general promotion.
  •  5© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNImpact of Career Moments1on Observations of MisconductBy Number of Career Moments in the Past Year (Excluding Promotions)0%25%50%PercentageofEmployeesObservingMisconductNoMoments5–10MomentsFourMomentsThreeMomentsTwoMomentsOneMomentBenchmark Average = 27.9%n = 3,311.INTRODUCING CHANGE RISKCareer moments havea significant impacton observations ofmisconduct, reportingrates, and perceptionsof integrity.■■ Employees experiencingtwo or more career momentsin a given year observetwice as much misconductas other employees.Impact of Career Moments on Employee Perceptions of IntegrityBy Number of Career Moments in the Past Year (Excluding Promotions)n = 3,311.EmployeePerceptionofIntegrityNoMoments5–10MomentsFourMomentsThreeMomentsTwoMomentsOneMoment-12%-6%0%A 4% decline is equivalentto moving from middle tobottom-quartile scores inperceptions of integrity.Career Moments andReporting■■ Employees morefrequently reportmisconduct as theyexperience additionalcareer moments.■■ Reporting ratesincrease mostsignificantly duringrole or team changes.1 Career moments excluding promotions.
  •  6© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNImpact of PromotionsNot surprisingly,promotions—particularlypromotions tomanager—decreaselevels of observedmisconduct.IDENTIFYING TOP CHANGE RISKSCompliance Risk1of Specific Career MomentsConsidering thelikelihood and impactof each career momentillustrates the magnitudeof change risk.■■ Career moments increaserisk by:–– Causing employee stress,–– Creating control gaps,–– Exposing employees tonew rules and operatingprocedures beforereceiving appropriatetraining, and–– Changing perceptionsof company integrityand willingness torationalize behavior.Corporate ChangesCompensation/BenefitChangesRole and Team ChangesTop Four Risks 21. Layoffs2. OrganizationalRestructuring3. Change in SeniorLeadership4. Change in JobResponsibilitiesPercentageofEmployeesObservingMisconductatMomentinPastYearPercentage of Employees Experiencing Moment in Past Year1 The CELC attempted to isolate the compliance risk of specific moments. While some moments do happen in tandem, factor analysis reveals a relativelylow and random relationships between specific moments.2 Risk Ranking is defined as the frequency of moments multiplied by the percent change in observed misconduct. This score represents the grosscompliance risk of a moment.0%15%30%0% 15% 30%LayoffsOrganizationalRestructuringChange in Job ResponsibilitiesChange in SeniorLeadershipChangein DirectManagerTransfer toNew TeamNoMomentsChange in theSkills You Use HiringFreezeWage FreezeReduction/Eliminationin Variable PayMandatoryUnpaidLeave/FurloughMerger/AcquisitionEarlyRetirementOfferReduction in Benefits
  •  7© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNTHE MAGNITUDE OF CHANGE RISKKey career momentstrigger significantincreases in specifictypes of misconduct.■■ Employees experiencingcorporate layoffs observe1.7x as much inappropriategiving, 3x as much bribery,3.5x as much fraud, and4x as much insider tradingas unaffected employees.What the Numbers MeanDuring layoffs, for every 10,000employees, an additional 500employees would observefraud.Observations of Inappropriate GivingPercentage of Employees Observing During Select MomentObservations of BriberyPercentage of Employees Observing During Select MomentObservations of FraudPercentage of Employees Observing During Select MomentNoMomentLayoffsOrganizationalRestructuringChangeinSeniorLeadershipChangeinJobResponsibilities0%5%10%3%5% 5% 5%9%Observations of Insider TradingPercentage of Employees Observing During Select Moment0%5%10%2%7%6%7%6%NoMomentLayoffsOrganizationalRestructuringChangeinSeniorLeadershipChangeinJobResponsibilities0%5%10%1%4%2% 2%3%NoMomentLayoffsOrganizationalRestructuringChangeinSeniorLeadershipChangeinJobResponsibilities0%5%10%2%6%5%4%5%NoMomentLayoffsOrganizationalRestructuringChangeinSeniorLeadershipChangeinJobResponsibilities
  •  8© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYN0%40%80%73%70%62% 61% 61%58% 58%56% 56%54% 54%50%48%35%REPORTING THROUGH CHANGEEmployee Reporting Rates1By Career MomentsEmployee reportingrates increase duringmost career moments.■■ Employees may feelmore willing to speak-up before they becomeinvested in workplacepractices and withnew colleagues.■■ Compliance and ethicsofficers should mine these“amnesty” periods whereemployees can criticallyreview workplace practicesand accepted norms.Role and team changes significantly increase reportingand represent a valuable opportunity to solicitinformation about workplace practices and culture.Role and TeamChangesCorporate ChangesCompensation/Benefit ChangesAReductionorEliminationinVariablePayLayoffsofTeamMembersAReductioninBenefitsASubstantialChangeinOneorMoreSeniorLeadersMandatoryUnpaidLeave-FurloughAHiringFreezeANewEarlyRetirementOffertoEmployeesAChangeinYourDirectManagerAMerger-AcquisitionATransfertoanEntirelyNewTeamAWageFreezeorSalaryCapASignificantOrganizationalRestructuringASignificantChangeintheSkillsYouAreUsingASignificantChangeinJobResponsibilitiesEmployeeReporting RateAt No Moments= 45%Reduction or elimination in variablepay (and compensation changesgenerally) may suppress reporting.n = Varies by moment.1 Reporting Rate—Percent of employees that report observed misconduct to an internal party (manager, compliance, helpline, etc.).
  •  9© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNTwo-thirds of employeesdo not receive theappropriate amountof information duringa career moment.■■ To relieve employee stress—and improve positiveoutcomes—the CELCidentified the attributesthat impact employeebehavior during careermoments.■■ The proper timing, channel,and content of complianceinterventions explains 40%of changes in employeeperceptions of integrityduring key career moments.NOT YET MEETING THE CHALLENGEEmployees Receiving Right Amountof Information1Percentage of Employees at Career Moment34%ReceivedAppropriateAmount ofInformation46%Neutraln = 2,218.1 Employees were classified as having “Received Appropriate Amount of Information” if they had scores of 5.0 or higher on a 7-point agreement scale.Scores below three were classified as “Not Receiving Appropriate Amount of Information.”2 Regression analyses were conducted to determine the aspects of outreach most indicative of higher perceptions of integrity and lower rates of observedmisconduct. While a wide range of demographic and independent variables were included in the model, the three variables above provided the highestlevel of explanatory power.20%Did NotReceiveAppropriateAmount ofInformationTiming of CommunicationChannel of CommunicationContent of Communication123Attributes of Effective Complianceand Ethics Interventions2
  •  10© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNCREATING EFFECTIVE INTERVENTIONSAttributes of Effective Compliance and Ethics InterventionsCELC identified theattributes of timing,channel, and messagewith the greatestimpact on employeeperceptions, misconduct,and engagement.■■ This research helpscompanies target theright employees withthe right message atthe most critical times.1 Timing—Employees were asked if they received compliance and ethics messages before, during, and/or after career moments.2 Channel—Employees were asked who they received communications from senior leaders, corporate functions (HR, Legal, Corporate Communications),managers (formally), managers (informally), peers, media, social media, and unions.3 Message—Employees were asked if they received six key messages surrounding the moment(s).Intervention Timing1Key AttributeCommunicate before (as soonas practical) a career moment.Intervention Impact■■ Reduces observationof misconduct by 20%.■■ Increases employee reportingrate by 5%.■■ Increases perceptions in integrityby 21%.Intervention Channel2Key AttributeUse direct managers tocommunicate through a careermoment.Intervention Impact■■ Reduces observationof misconduct by 21%.■■ Increases employee reportingrate by 34%.■■ Increase perceptions of integrityby 26%.Intervention Message3Key AttributeCommunicate the importance ofintegrity through a career moment.Intervention Impact■■ Reduces observationof misconduct by 37%.■■ Increases employee reportingrate by 54%.■■ Increases perceptions of integrityby 40%.Key TeachingReaching out to employees beforea career moment can mitigate theincrease in misconduct and declinein integrity almost entirely.Key TeachingEffective manager involvement at keycareer moments reduces misconductand significantly increases employeereporting.Key TeachingEmployees seek different messagesat different moments, but requirea foundation that empowers ethicaldecision making.
  •  11© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNPUTTING IT ALL TOGETHERIdeal Intervention AttributesCouncil AnalysisPotential Impact on EmployeePerceptions of IntegrityPercentage Change in Perceptions of Integrityby InterventionPotential Impact on EmployeeObservations of MisconductPercentage Change in Observations of Misconductby InterventionDelivering the mosteffective interventionsimproves employeeperceptions of integrityby 40% and reducesobserved misconductby almost two-thirds.■■ Effective interventionsactually improve employeeperceptions above pre-moment levels.■■ Change is not justan under appreciatedrisk, but a significantcompliance opportunity.Beforea career momentFromdirect managers+ Importanceof integrity+IdealIntervention 1Least EffectiveIntervention 2∆ = 73%1 Ideal intervention is made up of communication before the event, through a direct manager, and messages about the importance of ethicalintegrity. Least effective intervention is made up of communication after the event, through a formal channel, about the organization’s responseto misconduct.2 Ideal and least effective interventions were calculated by comparing the integrity scores for the various combinations of interventions.An intervention had to have at least 10 individuals experience it in order for it to be included.An ideal intervention increases perceptions above thelevel of employees who experience no moments.Timing Channel ContentIdealIntervention 1Least EffectiveIntervention 2Beyond Compliance:Business CaseIdeal interventions increase:■■ Employee engagementby 23%■■ Discretionary employeeefforts by 8%(23%)
  •  12© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNOVERVIEW OF SOLUTIONSToday’s sessionwill focus on leadingstrategies for buildinga moments-responsiveprogram that maximizesintegrity at key careermoments.1Integrate Complianceat Key Career Moments2Equip Managers toLead through Moments3Create Moment-Relevant MessagesEstablishing Tone at the Start Fostering Early EthicalLeadershipCreating Moments-Responsive MessageShaping AcquiredEmployee PerceptionsAligning Company Valuesto Managerial DecisionsMeasuringOrganizational HealthIdentifying Role-SpecificLearning NeedsEmbedding Compliancein Senior Manager PrioritiesSimulating Consequencesof Future DecisionsCELC Tools and ResourcesMoment-Specific Toolkits Ethical Leadership Portal ■■ Workforce Change Survey■■ Communications MessageGenerator
  •  13© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNOVERVIEWBayer delivers compliance and ethics outreach to new hires multiple times throughout their first year at theorganization, shaping perceptions of company values and compliance expectations early on. Additionally, deliveringmessages in a variety of formats reinforces desired behaviors during this key time in the employee life cycle.SOLUTION HIGHLIGHTSSend Messages Before Candidates CommitDeliver compliance and ethics outreach to potential new hires when they receive their offer letter to communicate thecompany’s commitment to integrity even before they accept the job.Reinforce Messages Across the First YearSend program outreach multiple times throughout the beginning of employees’ tenures to reinforce company valuesand compliance expectations when employees are most open to these messages.Vary Delivery ChannelUse multiple delivery formats to appeal to employees with a variety of learning styles and preferences.COMPANY SNAPSHOTBayer CorporationIndustry: Life Sciences Bayer Corporation, headquartered in Pittsburgh, is a subsidiary of Bayer AG,an international health care, nutrition and high-tech materials group basedin Leverkusen, Germany. Bayer, which created aspirin in 1897, manufacturersand sells pharmaceuticals, OTC drugs, medical devices and animal healthcare products through its Bayer HealthCare subgroup; plastics and high-performance specialty materials through Bayer MaterialScience; and cropprotection and home garden care items through Bayer CropScience. Aside fromBayer® Aspirin, the company’s best-known consumer brands include Aleve®,Alka-Seltzer™ and One A Day ® vitamins. Bayer AG has some 300 operatingsubsidiaries worldwide.2011 Sales: US$10.5 B 1Employees: 15,800ESTABLISHING TONE AT THE START1 Exchange rate as of 6 July 2012: US$1 = €0.8139.
  •  14© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNEXTENDING COMPLIANCE AND ETHICSONBOARDINGBayer’s Compliance and Ethics Onboarding TimelineIllustrativeRecognizing the firstmonths at the companyas a formative period foremployee perceptions,Bayer concentratesoutreach during thiscritical time.■■ Bayer managers onboardnew hires using a checklist,which includes specificcompliance tasks tocomplete in the first month.Month ThreeMonth SixDay OneDear Colleague, On behalf of the Corporate Compliance community, we would like to officially welcome you to Bayer!Attached is a copy of Bayer’s Corporate Compliance Policy. The Corporate Compliance Policy is essentially Bayer’s code ofconduct. It applies to everyone, at every level, and in every country where the company operates. Please read and internalize theobligations of this Policy as you will be expected to apply it to your daily work.As you will soon learn, Bayer’s core values are Leadership, Integrity, Flexibility and Efficiency. Together, they stand for “LIFE,” anacronym which can be easily remembered as it fits squarely with our motto: “Bayer: Science for a Better Life.” Although each valueis equally important, we would like to take this opportunity to emphasize the “I” or “Integrity.” Bayer is a company that takesgreat pride in its commitment to conducting business in accordance with all applicable laws, rules and regulations, as well as thehighest standards of ethical conduct. Acting with integrity, at all times, is at the heart of our operations, is critical for maintainingour brand and reputation, and for achieving sustainable success.Should you ever have any questions about the Corporate Compliance Policy, or wish to report a concern, please do not hesitateto contact a member of your management chain, your Compliance Officer, Law Department, Human Resources (for employmentmatters), Corporate Auditing, or for confidential inquires, by calling the Bayer IntegrityLine at +1 888-765-3846 or online DateRecruitment Year OneOne-on-oneconversation heldwith managerIn-person trainingled by localcompliance officerRisk-specific and otherbusiness unit compliancetraining continues (as needed)Compliance officer letterincluded with electronicoffer of employment8642Code of conductshowcased onrecruitment websitePaper code ofconduct distributed,accompanied by letterfrom compliance officerCode of conductonline trainingdeployedRisk-specific onlinetraining begins (e.g.,anticorruption, antitrust)Annual ethics course,including code ofconduct training andrecertification, launches97531“Communicating earlyand often duringonboarding hardwirescompliance and ethics intoemployees’ way of operatingwhen they are especiallyreceptive to adopting theorganization’s values andintegrating into its culture.”Keith AbramsVice President, Associate GeneralCounsel and Assistant SecretaryBayer Corporation
  •  15© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYN■■ Age■■ Company nowledge■■ Computer access■■ Learning style■■ Local culture■■ Role■■ Seniority■■ Time limitationsIndividualCharacteristicsOutreachRecipient,by ChannelPreference■■ Hard Copy■■ LIVE TRAINING■■ E-learning■■ Hard Copy■■ Live Training■■ E-LEARNING■■ HARD COPY■■ Live Training■■ E-learningDeliveryChannels,ExcerptedHard Copy■■ Code of conduct■■ Pocket guide (e.g., antitrust,corporate compliance)E-Learning■■ Code of conduct module■■ Trade compliance module■■ Workplace safetypresentationLive Training■■ In-person training with localcompliance officer■■ CEO Townhall■■ Monthly “Compliance Chat”and “Lunch and Learns”DEPLOYING ONBOARDING OUTREACHTHROUGH A VARIETY OF CHANNELSCompliance and Ethics Outreach DeliveryIllustrativeBayer delivers itscompliance and ethicsoutreach in a variety offormats to ensure keymessages are absorbedby all employees.■■ Multiple delivery channelsallow Bayer to scale itsonboarding outreach whileappealing to individuals’preferences.By the end of their firstyear at the company, allnew Bayer employeesreceive compliance andethics outreach througheach delivery channel,helping to ensure at leastone message formatresonates with everyindividual.
  •  16© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNOVERVIEWCentene organizes interactive training sessions with new and acquired employees to address compliance knowledgegaps as early as possible, and to understand employee perceptions about Centene’s ethical culture and commitmentto integrity.SOLUTION HIGHLIGHTSAddress Compliance Knowledge Gaps in the MomentAdapt live training for new employees based on the results of in-the-moment tests, allowing training facilitatorsto tailor and focus training time on the compliance risk areas that require additional reinforcement.Shape Perceptions of IntegrityConduct focus group sessions with new employee populations to understand and influence their perceptions ofcompany integrity during their first months at the organization, a critical period of increased employee receptivity.COMPANY SNAPSHOTCentene CorporationIndustry: Health Care Centene Corporation provides managed care and related services in morethan a dozen states under names such as Managed Health Services, SuperiorHealthPlan, and Buckeye Community Health Plan. Centene provides servicesto some 2.39 M low-income, elderly, and disabled people receiving Medicaid,Supplemental Security Income, and state Children’s Health Insurance Program(CHIP) benefits. Centene also offers specialty services in areas such asbehavioral health, vision benefits, and pharmacy benefits management.2011 Revenue: US$8.2 BEmployees: 6,800SHAPING ACQUIRED EMPLOYEE PERCEPTIONSOF COMPLIANCE AND ETHICS
  •  17© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNINTEGRATING ACQUIRED EMPLOYEESCentene’s Acquisition ProcessSelect Compliance and Ethics ActivitiesDeliver early outreachto newly acquiredemployees to understandand address theircompliance andethics needs.■■ Centene uses a live pollingtechnology to promoteactive discussions oncompliance risks andintegrity concerns with newemployees.Due Diligenceand PlanningImplementationof Integration PlanClosingPost-ImplementationPlanning andMonitoringI. Risk-Specific Compliance Training II. Cultural Focus Group Discussion■■ Typically, 30 to 60 days after closing■■ Identifies baseline compliance knowledge andneed for follow-up training.■■ 60–90 days after closing■■ Informs Compliance about local perceptions ofcompany integrity.Pre-Training Session QuizCode of ConductEnd-of-Training QuizCode of Conduct■■ If an employee witnesses a compliance violation,what should he or she do?The False Claims Act■■ Under the False Claims Act an organization can befined up to $33,000 per false claim submitted.True or False?Privacy and Security■■ Large breaches of health information must bereported to the media. True or False?Anti-Kickback Statute■■ Case managers are allowed to accept finders’ fees forreferring members to a provider. True or False?LocalComplianceOfficerQuestion 1Yes No
  •  18© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNI. ADDRESSING EMPLOYEE KNOWLEDGE GAPSIN THE MOMENTCentene’s Risk-Specific Implementation TrainingIllustrativeTo mitigate acquiredemployees’ knowledgegaps about specificregulatory risks, Centenedynamically tailors livetraining based on in-session quiz results.■■ Responses to live pollingallow Centene to instantlymeasure employeeunderstanding of keycompliance risks.Quiz QuestionsCode of Conduct■■ Employees can accept vendor gifts and thereis no dollar limit to what they can accept.True or False?The False Claims Act■■ Under the False Claims Act an organizationcan be fined up to $33,000 per false claimsubmitted. True or False?Privacy and Security■■ Large breaches of health information must bereported to the media. True or False?Anti-Kickback Statute■■ Case managers are allowed to accept finders’fees for referring members to a provider.True or False?Keeping Quizzes Short: Centene limits itsquizzes to no more than 10 questions toallow more time for group discussion.Implementation Training AgendaObjective: Compliance-risk awareness discussionFacilitator: Local Compliance Officer or VP of Ethics andComplianceAudience: Groups of around 10 new or acquired employeeswith similar job functions so that discussions can be basedaround job-specific risks.Length: 2+ hoursTopics Covered■■ Code of Conduct■■ The False Claims Act■■ Privacy and Security■■ Anti-Kickback StatuteThree Quizzes1. Pre-training quiz: Sets the tone for an initial discussion onkey compliance risks.2. Post-training topic quizzes (2–3 questions per topic): Testsemployee knowledge following individual compliance riskdiscussions to gauge the need for further discussion duringpresentation.3. End-of-training quiz: Re-tests employee knowledgefollowing training discussions.Post-Training Follow-Up: Local Compliance rolls out furthertraining to groups of employees who have scored particularlylow on training quizzes.
  •  19© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNII. (RE)SHAPING PERCEPTIONS OF INTEGRITYCentene’s Cultural Focus GroupIllustrativeCentene conducts livefocus group sessionswith new and acquiredemployees to set andreinforce the company’scommitment to operatingwith integrity.■■ Centene uses live pollingto surface employeeperceptions and frame thediscussion in the momentbased on employeeresponses.Focus Group AgendaObjective: Integrity discussionFacilitator: Local ComplianceOfficer or VP of Ethics andComplianceAudience: A sampling of the newlyacquired employee population ingroups of 10–15Length: Typically two hoursPost-Session Activities■■ Share Employee Feedbackwith Local Leadership:Centene provides localleadership with a summaryof the feedback collected ineach session.■■ Communicate with Staff:Leaders use this informationto address employee concerns.Typical next steps includeall-employee meetings, CEO-staff lunch and learns , andcommunications campaigns.Pre-Session Messaging■■ Outreach to Employees:Selected employees receive aninvitation e-mail introducingthe session as a platform foremployees to express theircompliance- and ethics-relatedconcerns.■■ Outreach to Local Leaders:To establish managementbuy-in and support for thesession, Centene meets withlocal leaders to explain thepurpose of the session.Discussion Questions, Excerpt:1. Have you observed misconduct?■■ Follow-up question: What kind of misconduct did you observe?2. Are you comfortable speaking up?■■ Follow-up question: What prevents you from speaking up?3. Are you comfortable raising concerns with your manager?■■ Follow-up question: Why are you uncomfortable raisingconcerns with your manager?LocalComplianceOfficerYes NoQuestion 1
  •  20© 2013 The Corporate Executive Board Company.All Rights Reserved. CELC5704813SYNCAPITALIZING ON NEW BEGINNINGSDiscussion-basedsessions for newemployees allow Centeneto communicate whenemployees are mostreceptive to receivingkey messages.“We’ve had very positive employeefeedback. Polling the audience in real timemakes training more interactive and engagingfor them, and hugely informative andactionable for us. I’m so convinced about thevalue of these sessions that I’ve budgeted topurchase additional polling equipment thisyear and use this training format with existingCentene employees.”Robert MiromontiVP, Ethics and ComplianceCenteneLessons Learned 1. Keep Groups SmallCentene learned that larger groups ofemployees are less likely to speak up duringsessions, and now keeps group sizes toabout 10 employees. 2. Allow for Longer Risk DiscussionsAfter finding that employees were eagerto engage in discussions during therisk training, Centene now allocates anadditional thirty minutes to these sessions. 3. Offer “Closed-Door” MeetingsCompliance staff is also available outsideof the formal session times for “closed-door” meetings with employees who feeluncomfortable speaking during focusgroups. 4. Provide an Adjustment PeriodCentene initially rolled out focus groupsessions immediately following theacquisition closing. Now it waits two tothree months to host sessions, which letsemployees gain knowledge and perspectiveabout new company management beforeparticipating in a focus group.Key BenefitsReduced Compliance FailuresDelivering training early duringimplementation clarifies important riskinformation, ensuring employees areprepared to meet compliance obligationsbefore they conduct business on behalf ofCentene.Improved Perceptions of IntegrityResponding to concerns during focus groupsessions improves employee perceptionsof integrity and establishes an importantrelationship of trust between employeesand the new company.
  • CEB Compliance and Ethics Leadership CouncilTo learn more about CEBCompliance and Ethics, please