Transcription
Speak Up!Encouraging and Responding to Employee ReportingSociety of Corporate Compliance and Ethics29 April 2011Chicago, IL USAMaurice L. Crescenzi, Jr.Global Compliance and Ethics OfficerDeVry Inc.
DeVry’s Global OrganizationDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
“Speaking Up” Program Objectives Empower employees to know why, when, and how tospeak up Encourage employees to come forward in good faithwithout fear of retaliation Ensure matters are logged, tracked, and closed out ina robust case-management system Ensure that all matters are reviewed or investigatedconsistently, efficiently, and effectively Close-outs, reporting, and trendingDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Speaking Up: Program ComponentsCode of Conductand“Speaking Up”“PolicyTraining,Communications,and AwarenessMaterialsTrending,Analysis, andReportingSpeaking UpProgramInvestigations andCaseManagementIn-take Systemsand MechanismsCentralized GCECaseManagementSystemDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Speaking Up: Program ComponentsCode of Conductand“Speaking Up“PolicyTraining,Communications,and AwarenessMaterialsTrending,Analysis, andReportingSpeaking UpProgramInvestigations andCaseManagement Encourages a cultureof compliance andethics Establishesexpectation thatemployees shouldask legal, policy,compliance, andethics questions;raise concerns; andreport suspectedwrongdoing. Explains SpeakingUp systems andmechanisms. Zero-toleranceregarding retaliation. Zero-toleranceregarding bad-faithreporting.In-take Systemsand MechanismsCentralized GCECaseManagementSystemDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Code of Conduct and Ethics
Tone at the Top
Speaking Up Chapter
Setting the Expectation
Defining Compliance and Ethics Issues
Defining Employee Relations Matters
Speaking Up Resources
Anonymity and Confidentiality
Zero Tolerance
Speaking Up Ticklers Throughout
Compliance PoliciesCode of Conduct and EthicsDeVry Inc. Compliance PoliciesDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Speaking Up PolicyDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Speaking Up Policy Establishes expectation of employees to come forwardEncourages the “first stop” to be a discussion with managerReminds that employee-relations matters should be directedto Human ResourcesProvides other Speaking Up channels: Manager’s managerHuman ResourcesLaw DepartmentGlobal Compliance and EthicsCompliance and Ethics HelpLine or HelpSiteZero tolerance for retaliation and bad-faith reportingAnonymity and confidentialityManagers’ responsibilitiesDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Speaking Up: Program ComponentsCode of Conductand Speaking UpPolicyTraining,Communications,and AwarenessMaterialsTrending,Analysis, andReporting Employeecommunications Awareness andinstructional posters,brochures, etc. Information onCompliance intranetsite Included in e-learningcoursesSpeaking UpProgramInvestigations andCaseManagementIn-take Systemsand MechanismsCentralized GCECaseManagementSystemDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Maurice L. Crescenzi, Jr.Global Compliance and Ethics OfficerDeVry Inc.
In-take Systems Code of Conductand Speaking UpPolicyTraining,Communications,and AwarenessMaterialsTrending,Analysis, andReportingManagerManager’s managerHuman ResourcesLaw DepartmentGlobal Complianceand EthicsDepartment Compliance andEthics HelpLine orHelpSite)Speaking UpProgramInvestigations andCaseManagementIn-take Systemsand MechanismsCentralized GCECaseManagementSystemDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Awareness Materials Employees encouraged to askquestions and raise concerns Several “speaking up” resources: Manager Manager’s manager Global Compliance and EthicsOfficer DeVry Legal Human Resources Compliance and EthicsHelpLine / HelpSite. Employee-relations matter shouldbe referred to Human ResourcesDeVry Inc.Global Compliance and Ethics
Speaking Up Program
Speaking Up: Program ComponentsCode of Conductand Speaking UpPolicyTraining,Communications,and AwarenessMaterialsTrending,Analysis, andReporting Case managementsystem allows us tocollect, categorize,prioritize, and relayall “intake” to SMEsfor handling. Categories aresubdivided by priority/ severity Case managementsystem can sendcopy of reports to keystakeholders.Speaking UpProgramInvestigations andCaseManagementIn-take Systemsand MechanismsCentralized GCECaseManagementSystemDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Case Management System Case-management system managed by Global Complianceand Ethics Cases routed to appropriate departments / SMEs for reviewand handling Close working relationship with key functions, like HumanResources Other functions leverage same case-management platform More efficient routing and handling of cases Macro trending and reportingDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Speaking Up: Program ComponentsCode of Conductand Speaking Up“PolicyTraining,Communications,and AwarenessMaterialsTrending,Analysis, andReporting Case Managementand Investigationspolicy establishesconsistent practicesrelated to the whens,whos, and howsrelated toinvestigations.Speaking UpProgramInvestigations andCaseManagementIn-take Systemsand MechanismsCentralized GCECaseManagementSystemDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Case Management and Investigations Policy Cross-functional effort led by Global Compliance and Ethics Sets forth the principles that should be adhered to for allformal investigations Lays out the steps that should comprise any formalinvestigation Determine the need for an investigationIdentify the lead investigator Outline the case Notify appropriate members of management Develop investigations plan Gather documentation and conduct interviews Write report Follow upDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Closing the Ethics Loop Formal report and executive summary Share findings with key members of managementand Human Resources Investigator recuses himself / herself fromdiscussions related to discipline Case closed in the case-management system Global Compliance and Ethics Officer follows upwith reporterDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Speaking Up: Program Components“Speaking Up“PolicyTraining,Communications,and AwarenessMaterialsTrending,Analysis, andReporting Case managementsystem allows casemanager to identifytrends. Robust reportgenerating. Case managerconnect trends toERM processSpeaking UpProgramInvestigations andCaseManagementIn-take Systemsand MechanismsCentralized GCECaseManagementSystemDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Reporting, Trending and MeasuringQuarterly reporting to the Audit Committee of the Board Top-line numbers Potentially significant matters called out in more detailCross-functional Business Process and Risk ManagementTeam Compliance and Ethics data shared Trends identified and relayed to SMEs Action plan developed by appropriate SME or leaderGlobal Compliance and Ethics SurveyDeVry Inc.Global Compliance and EthicsGuidance. Collaboration. Excellence.
Global Compliance and Ethics OverviewThank YouMaurice L. Crescenzi, Jr.Global Compliance and Ethics Officer 1 630 353 9919Mcrescenzi@devry.comDeVry Inc.Global Compliance and Ethics
to Human Resources Provides other Speaking Up channels: Manager's manager Human Resources Law Department Global Compliance and Ethics Compliance and Ethics HelpLine or HelpSite Zero tolerance for retaliation and bad-faith reporting Anonymity and confidentiality Managers' responsibilities DeVry Inc.
