Best practices for designing effective ethics programmes

Contents

• Foreword: Why ethics has re-emerged as a critical management issue, and how companies are responding with the development of ethics policies and training programmes
• Acknowledgements
• Executive Summary

1. Section 1: Corporate policy development
   1. The business case for having an ethics policy
      An analysis of the drivers behind developing an ethics programme
   2. Values first
      The need to base ethics programmes around a key set of corporate values and principles Company insight 1: Samarco - changing company culture
   3. What an effective ethics policy includes
      Issues typically covered by Codes of Conduct and charters of ethics
   4. Managing the process
      Key steps in managing the development or revision of ethics policies, noting the importance of consultation Company insight 2: Rio Tinto - revising its code
   5. Cultural relevance
      • Company insight 3: Tata - multicultural ethics
      • Company insight 4: Rio Tinto - Global codes versus local codes
      • Company insight 5: GDF Suez - tapping local knowledge
   6. Developing an anti-corruption policy
      An introduction to corruption as a business issue, relevant international standards and approaches to developing specific internal policies to combat corruption
      • Textbox 1: What exactly is corruption?
      • Textbox 2: The top ten industries most affected by corruption
      • Textbox 3: What does corruption look like in practice?
      • Case study 1: Standard Chartered Bank - developing a specific anti-corruption policy
2. Section 2: Business ethics training
   1. Creating a corporate training programme
      Information on management roles and responsibilities, use of consultants, management time, key subject areas, training frequency, training methodologies and contextual relevancy
      1. Approach
      Company insight 6: Xstrata - training in stages
      2. Consultants
      3. Time
      4. Subject area
      5. Frequency of training
      6. Methods
      Company insight 7: Rio Tinto - scenario training
      7. Context
         • Case study 2: Inter-American Development Bank - cultural adaptation
   2. Audience
      Meeting the need for basic corporate-wide training as well as tailored training for specific employee categories such as management leaders, at-risk employees, remote workers, ethics officers and suppliers
      1. Senior management
      Company insight 8: Coca-Cola - demonstrating senior management commitment
      2. At-risk managers
      3. Hard-to-reach employees
      4. Ethics officers
         • Case study 3: Intel - putting business champions to work
      5. Suppliers
   3. Training delivery
      A description and evaluation of online and face-to-face approaches, plus information on training deliverers
      1. Tools
      2. Training facilitators
      3. Online
         • Case study 4: Novartis Land
      4. In-person training
      5. Textbox 4: A framework for decision-making
   4. Monitoring training
      Systems to track and evaluate participation and effectiveness of training programmes
   5. Training costs
      Examples of positive outcomes from effective training programmes, the budgets required and the barriers to success
   6. Training benefits
      An examination of the positive outcomes derived from a successful ethics training programme
3. Section 3: Anti-corruption training in large companies
   1. Trainee selection
      Job functions typically identified as 'at risk' of corruption
      • Case study 5: Wal-Mart Brazil - multi-layered training
   2. Content & delivery
      • Textbox 5: Sample scenario: conflict of interest - 'We didn't have this conversation'
      • Textbox 6: Anti-corruption training: Merck, Q & A style
      • Case study 6: Anti-corruption video training
4. Section 4: Stakeholder communications around ethics
   1. Internal communication
      An assessment of the importance of an internal communications strategy on ethics and the tools to achieve it
      1. Engaging senior management
         • Case study 7: Amec - communicating with senior management
         • Case study 8: Intel - establishing an ethics portal for managers
      2. Communicating company wide with employees
         • Case study 9: Dell - ethics blogging
         • Case study 10: Lockheed Martin - 'Integrity Minute'
   2. External communication
      An overview of communication practices oriented towards external stakeholders
      1. Effective external communications
      2. Tools for external communications
         • Table 1: Xstrata grid
         • Case study 11: Shell - telling it as it is
5. Section 5: How big firms manage successful compliance
   1. Best practices in monitoring and auditing ethics programmes
      Internal audit and external due diligence to ensure the implementation of ethics programmes
      • Text box 7: What business executives have to say about monitoring corruption
   2. Due diligence
      Tools for employees to report non-compliance, together with investigation and disciplinary measures
      • Case study 12: Wal-Mart Brazil - background checks on suppliers
      • Case study 13: Consultant for multinationals - carrots not sticks in China
   3. Employee reporting
      • Text box 8: Whistleblower Protection under Sarbanes Oxley

• Appendix A: Code of Conduct training examples
• References