Anti-Corruption and Anti-Bribery

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APPENDIX 5-B: Considerations in Initially Planning or Reviewing Your Training Program

To begin your planning process or assessment it may be helpful to determine the following:

What are the objectives for the training?

☐ Support a culture of ethical behavior and compliance.

☐ Communicate a policy, requirement or law to raise awareness and improve compliance, also reduce risk. Provide practice in applying policy to realistic scenarios.

☐ To satisfy internal or external obligations or requirements.

☐ To help close a known gap in behaviors revealed in assessment, audit, or investigation.

What issues to cover and who to train?

What are the highest risks?

___________________________________________________

What current training exists?

___________________________________________________

How effective is existing training?

___________________________________________________

How will you address specialized or complex topics?

___________________________________________________

Will employees or others be learning processes and systems?

___________________________________________________

Who interacts with the risk and at what level?

___________________________________________________

In anti-corruption training, audience would focus on:

☐ Positions with high levels of discretion (board, senior management, CFO, Controller)

☐ Positions in countries considered high-risk (e.g., country managers, local finance, sales reps)

☐ Sales and marketing groups that operate in global environments

☐ Procurement and supply chain organizations (financial influence, many third-party relationships, etc.)

☐ Legal, finance, and ethics and compliance (must have a deeper knowledge of standards for advice giving and exercise of approval authority)

☐ Employees otherwise expected to be involved in situations where specialized or complex information is needed to manage specific risks (for ex. putting together a first time deal in a remote, high risk location)

☐ Third parties

What is the current training load for these individuals and how can you best access the employees?

How much learning needs to take place?

___________________________________________________

☐ Increased awareness plus where to go for help

☐ Deeper understanding and changed beliefs

☐ Application, advocacy and changed behaviors

How will you present materials, with what frequency and depth of content?

☐ Review of law, guidelines and best practices

☐ Consideration of how your population learns

☐ Provision of a variety of reinforcing approaches

☐ Setting of goals and plan to measure progress.

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