Principled

We’ve officially wrapped season eight of the Principled Podcast and are taking a break for the holidays. Stay tuned for more conversations on culture, ethics, and compliance in the coming calendar year. Happy holidays!

It’s no secret that writing a code of conduct doesn’t change your company culture overnight. It’s important to develop training that educates your employees on what’s included in your code, and how those elements apply to their day-to-day work. But how can you do that in a way that makes your code dynamic and accessible? On this Principled Podcast episode, host Jim Walton talks to Chris Dunstan, the Chief Compliance Officer & Group General Counsel at SPX FLOW, about how the company tailored its code of conduct training to better reflect the responsibilities of employees, while also keeping the material interactive and connected to its evolved brand. The training has received enthusiastic industry recognition, winning gold at this year’s Brandon Hall Awards for Best Advance in Compliance Training. More importantly, the training has reached a record-high completion rate across SPX FLOW’s global offices.    Featured guest: Chris Dunstan   Chris Dunstan is a versatile legal leader with an aptitude for legal operations, strategy, and optimizing the intersection of business and the law. He is the Chief Compliance Officer & Group General Counsel at SPX FLOW, a diversified manufacturer of industrial equipment with operations in more than 30 countries. In this role, he manages the global litigation docket and compliance program and leads a team responsible for all commercial legal activities for multiple product portfolios. Prior to joining SPX FLOW, Chris was the general counsel at Lucifer Lighting and spent more than a decade working as the senior litigation counsel for Ericsson.  Chris has spent much of his career helping both public and private companies navigate complex legal issues in dynamic, highly regulated industries such as telecommunications, consumer products, and industrial equipment manufacturing. He always strives to share his deep functional expertise in high-stakes litigation, IP protection and licensing, foreign and domestic regulatory compliance (FCPA / UK Bribery Act / GDPR / CCPA), and commercial transactions.     Featured host: Jim Walton   Jim Walton is a member of LRN’s Ethics & Compliance Advisory Services Team – with over 25 years of professional experience in corporate, institutional and government settings, spanning the fields of ethics and compliance; environment, health and safety; and energy management. Since 2002, Jim has been passionately dedicated to corporate ethics and compliance – designing, developing, implementing and enhancing constantly-evolving, comprehensive, best-in-class, global ethics and compliance programs. Jim has extensive experience in writing, producing and communicating codes of conduct and corporate policies; designing, managing and implementing ethics & compliance risk assessments; implementing anti-compliance and bribery initiatives; conducting third-party due diligence reviews; and helping managers at all levels become better ethical leaders. Jim is a Certified Compliance and Ethics Professional.   For a transcript of this podcast, please visit the episode page at LRN.com.

As today’s societal issues continue to mount, employees are turning to the workplace as one of the safer spaces for debate and a primary source of community. In fact, data from a special edition of Edelman's 2022 Trust Barometer—specifically analyzing trust in the workplace—notes that 78% of employees trust their employer over other established institutions and connections. So, how can companies leverage trust and adapt their own practices to better address employee concerns? In this episode of the Principled Podcast, host Emily Miner explores key findings from the Trust in the Workplace report with David M. Bersoff, the Head of Research at the Edelman Trust Institute. Listen in as the two discuss what drives trust and how employers can strengthen trust in—and beyond—the workplace.  Get a copy of the Edelman's Trust in the Workplace special report.    Read our blog post on takeaways from this report.    Featured guest: David M. Bersoff, Ph.D. As the Head of Research for the Edelman Trust Institute, Dr. Bersoff is the lead researcher on all of Edelman's trust-oriented thought leadership, including the Edelman Trust Barometer. He also leads the Institute's research-based collaborations. Prior to joining Edelman in 2016, David spent 18 years as a consumer insights and marketing strategy consultant at The Futures Company. In his last 5 years with the organization, he served as its Chief Insights Officer and was a member of its global board of directors. In that role, he ran the Global Insights Group and drove the research, data analysis, IP creation and product development strategy for all of their syndicated consumer insights offers – Yankelovich MONITOR, Multicultural MONITOR, Global MONITOR, Health and Wellness MONITOR, Financial Services MONITOR, and the TRU Youth MONITOR.  In addition to his background in IP development and insights product management, David has also served as a trusted advisor and marketing/brand strategy consultant to major clients in industries as diverse as financial services, automotive, media, professional organizations, energy, and the military. Prior to entering the consulting world, David spent 12 years engaged in social science research at various Ivy League institutions, including 4 years as an assistant professor of social psychology and research methodology at the University of Pennsylvania.   Featured host: Emily Miner Emily Miner is a director in LRN’s Ethics & Compliance Advisory practice. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.   For a transcript of this episode, visit https://blog.lrn.com/islands-of-civility-a-special-edelman-report-on-trust-in-the-workplace      

In this episode of the Principled Podcast, host Susan Divers continues her conversation from Episode 11 with Tom Fox, the founder of the Compliance Podcast Network, on the changing geopolitical landscape and its impact on E&C. Listen in as the two discuss how anti-corruption is a key component of ESG, the consequences of compliance in cybersecurity, and the growing interconnectedness of risks. You can listen to Episode 11 here.  To learn more, download a copy of Tom Fox's white paper Never the Same: Five Key Areas in Which Business Will Never Be the Same After the Russian Invasion.    Featured guest: Tom Fox Tom Fox is literally the guy who wrote the book on compliance with the international compliance best-seller The Compliance Handbook, 3rd edition, which was released by LexisNexis in May 2022. Tom has authored 23 other books on business leadership, compliance and ethics, and corporate governance, including the international best-sellers Lessons Learned on Compliance and Ethics and Best Practices Under the FCPA and Bribery Act, as well as his award-winning series "Fox on Compliance." Tom leads the social media discussion on compliance with his award-winning blog, and is the Voice of Compliance, having founded the award-winning Compliance Podcast Network and hosting or producing multiple award-winning podcasts. He is an executive leader at the C-Suite Network, the world’s most trusted network of C-Suite leaders. He can be reached at tfox@tfoxlaw.com.   Featured host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years’ accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.  Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.  Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: Hello and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, Director of Thought Leadership and Best Practices at LRN. Today, I'm continuing my conversation from episode 11 with Tom Fox on the changing geopolitical landscape and its impact on ethics and compliance. If you haven't listened to that episode yet, we highly encourage you to do so. Tom is the founder of the Compliance Podcast Network and the author of the award-Winning FCPA Compliance and Ethics Blog, as well as the Complete Compliance Handbook, which is in its third edition. Tom, welcome back to Principled Podcast. Tom Fox: Thank you, Susan. Susan Divers: Tom, in our last episode, we talked about the impact of the war in the Ukraine on compliance and ethics. And specifically on the challenges that's imposed or brought to the fore for companies and specifically for their compliance teams who hopefully have a real seat at the table in terms of dealing with those challenges and mitigating those risks. But one of the topics that underlies what we were talking about is that of conducting your business in a fair, transparent, and sustainable manner. And I'm really struck by some of the things you were saying about the need to be transparent and the need to walk the walk and talk the talk. Because if you fail to do so, we live in an age of radical transparency and easy access to social media, and moreover, it's the right thing to do. So with that as the background, anti-corruption has long been a focus for regulators. I mean, it's probably defined yours and my careers in a lot of regards. But only recently have some people started talking about it, and you're one and I'm one, as a major component of ESG. Could you explain for our listeners how that works and the role of anti-corruption in ESG? Tom Fox: Sure. So ESG, in my mind, Susan, the power of ESG is that it has brought together disparate strands that have existed in every corporation for some lengthy period of time. But brought them together in a way that someone is looking at them holistically. So, I'll pick on E because that perhaps is the easiest. As a compliance officer, I never looked at environmental issues in our company. That was somebody else's responsibility. Susan Divers: Me either. Right. Tom Fox: Didn't mean there wasn't environmental compliance, but it meant that I wasn't looking at that from the compliance perspective. Now, whether it's the Chief Sustainability Officer, whether it's the Board of Directors, whether there's a Board ESG Committee, somebody's connecting compliance to environmental. And so that in and of itself is, to me, the most powerful reason to have a robust ESG program. But anti-corruption in ESG, in my opinion, Susan, I've always seen it directly in the G. Susan Divers: Me too. Tom Fox: Number one, it's a good governance issue. Number two, it is a Board of Director's issue. Number three, it's illegal and regulatory issue. But now Susan, I'm beginning to see it and have tried to articulate, that I see it in the S component as well as sustainability. Part of it is around one of the topics we touched on our last podcast of radical transparency, that if you do business ethically and in compliance, and if there's a question raised about a supplier, a customer, a distributor, a someone you've done business with in today's era of modern social media, that you can respond to that in a way that won't hurt your business from the public perception perspective. Leaving completely aside the regulatory perspective. So, I see ABC or anti-corruption compliance now, Susan, as directly within the S of ESG as well. And I also see it in the E. So to me, it sort of bleeds across all aspects of ESG and is a key component of a best practices ESG program. Susan Divers: Yeah, and I'm glad you articulated it so clearly for people, because I think there's a tendency perhaps, to silo ethics and compliance and sustainability. And they really are part and parcel of the same thing. And I'm going to quote from your recent white paper in support of that. "As a fundamental threat to the rule of law, corruption hollows out institutions, corrodes public trust, and fuels popular cynicism towards effective accountable governance." And that's, I think, a quote from the U.S. Strategy on Countering Corruption. Can you talk for us and link together how anti-corruption, anti-money laundering, and sanctions all are part and parcel of the same thing and relate to ESG? I think that'd be helpful for our listeners? Tom Fox: So Susan, the statement you read interests me for a couple of reasons. That came out of the U.S. Strategy on Countering Corruption, and it was aimed at national governments, so national governance. And I think it's absolutely correct that corruption, money laundering, all fuel cynicisms towards effective, accountable national governance. But Susan, as you were reading that, it struck me, that is equally true about corporate governance, or the G in ESG. Because violations of the rule of law, corruption, money laundering, they all corroded trust in our corporations, and indeed fuel cynicism towards effective accountable corporate governance. The United Nations estimates that $3 trillion is lost to the global economy annually because of bribery and corruption. The United States Department of Treasury estimates that $2 trillion is lost annually because of money laundry. That's $5 trillion taken out of the global economy that could be used for a wide variety of other ways, reasons to help countries and people that's not available to them. So having an effective anti-corruption and anti-money laundering strategy as well as trade sanctions, I think, are directly a part of ESG. They're certainly all in the G. We've talked about how they relate to sustainability. But money laundering and trade sanctions are as invidious, in my mi

As the world emerges from a pandemic mindset, we find ourselves confronting new geopolitical realities with Putin's war in the Ukraine as well as increasingly fraught relations between the US and China. How is this geopolitical landscape changing the compliance landscape? In this episode of the Principled Podcast, host Susan Divers is joined by Tom Fox, the founder of the Compliance Podcast Network and aptly accredited “Voice of Compliance.” Listen in as the two discuss the impact of geopolitics on ethics and compliance, and what issues should be top-of-mind for E&C leaders in the near future. To learn more, download a copy of Tom Fox's white paper Never the Same: Five Key Areas in Which Business Will Never Be the Same After the Russian Invasion.   Featured guest: Tom Fox Tom Fox is literally the guy who wrote the book on compliance with the international compliance best-seller The Compliance Handbook, 3rd edition, which was released by LexisNexis in May 2022. Tom has authored 23 other books on business leadership, compliance and ethics, and corporate governance, including the international best-sellers Lessons Learned on Compliance and Ethics and Best Practices Under the FCPA and Bribery Act, as well as his award-winning series "Fox on Compliance." Tom leads the social media discussion on compliance with his award-winning blog, and is the Voice of Compliance, having founded the award-winning Compliance Podcast Network and hosting or producing multiple award-winning podcasts. He is an executive leader at the C-Suite Network, the world’s most trusted network of C-Suite leaders. He can be reached at tfox@tfoxlaw.com.   Featured host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years’ accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.  Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.  Principled Podcast Transcript   Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: General Pete Schoomaker made a remark some years ago that's always stayed with me. He said, "People like to think that life is an opera that unfolds over several acts, but it's really a rodeo. You never know what's coming out of the shoot." So much of the ethics and compliance sphere clearly demonstrates the truth of the general's remarks, especially recently. LRN's last two program effectiveness reports focused specifically on the impact of the pandemic on ENC programs. Now we have the war with Russia in the Ukraine and increasingly fraught relationships with China. How is the geopolitical landscape changing the compliance landscape? Hello and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, director of thought leadership and best practices at LRN. Today, I'm joined by Tom Fox, the founder of the Compliance Podcast Network and aptly accredited Voice of Compliance. In addition to his 30 plus years of legal experience, Tom is the author of the award-winning FCPA Compliance and Ethics blog, and The Complete Compliance Handbook now in its third edition, which is by far the best source for best practices in one place about ENC programs. We're going to be talking about the impact of geopolitics on ethics and compliance and what issues should be top of mind for ENC leaders in the near future. Tom, welcome. Tom Fox: Susan, thanks. I have wanted to be on this podcast for a long time. I particularly enjoyed your reference about rodeos because in the great state of Texas, that's a college sport, rodeoing, so lots of rodeos and it's certainly an apt metaphor for what we're going to talk about today. Susan Divers: Well, great, Tom and I really appreciate the opportunity to have any conversation with you, but particularly on the podcast. So Tom, first, generally, how do you see the ongoing war in the Ukraine as disrupting trade and the rules, both formal and informal, that have governed the world for the last 20 years and is the World Economic Forum vision of trade now dead? Tom Fox: Susan, in addition to the rodeo metaphor you gave us, the most prescient comment I heard during the COVID-19 pandemic is that we've moved from disaster recovery to business interruption to, excuse me, to business resiliency, to business as usual. Literally now, we can have a weather event, we can have an economic event, we can have a geopolitical event, we can have any event and the requirement of a company is how do you respond? How do you respond tomorrow? Have you planned for this? I think the type of thing that we saw with the Russian invasion, as tragic as that was, it's one more, it's just an event and we're going to talk about that in some detail. But every company has legal, ethical and business obligations around that event. I was also particularly struck by your reference to the World Economic Forum, and when I read that, it put a frown on my face. And it put a frown on my face because the World Economic Forum, in my mind, has been one of the biggest leaders for the global economy. Since at least 1990 when I started paying attention to a global economic framework because I was in the energy industry and began to think about these issues on a global basis, the World Economic Forum and their symposiums, their position papers and really their raison d'etre was to talk about a global economy. Although I certainly thought we would have regional conflicts, as we have always had, I never thought we would, I guess my hope was that the global economy would help drive us towards a more integrated global community and that we wouldn't be put near a brink again of a global conflict. I don't pretend to say that's where we're going in Ukraine, but when you start talking about tactical nuclear weapons, that's a conversation we haven't had in this country since the '60s with seriousness. The World Economic Forum, the world they envision, the world you and I grew up in professionally, I think that world is gone. We're moving to something else. I use the Russian invasion of Ukraine really as an ending point or an exclamation mark on trends that we have seen percolating probably 10, 5, 3 years that accelerated extraordinarily greatly in the COVID-19 pandemic up to the war in Ukraine and the disruption that that has caused really impacts businesses, and this is going to be something, I think, we're going to have to deal with literally on an ongoing basis forward. Lots, really, to unpack there, but I do have to acknowledge you for pointing out it was really the World Economic Forum that has led, I thought, the charge for a global economy and globalization and unfortunately, I think that world is now dead. Susan Divers: I hear you and I feel the same way about the Forum. LRN participated in it quite actively until fairly recently, and the Forum really did an excellent job of helping global leaders cooperate, frame some of the rules and the practices. Maybe when the current situation resolves itself one way or another, there'll be an opportunity to do that again. But getting a little bit more granular at this point. You've written about the impact of the Ukrainian war on the supply chain and certainly for business that's one area where the rubber really hits the road. Can you explain that a bit to our listeners? Tom Fox: Sure. The Ukraine War, the Russian invasion of Ukraine, as I said, put a exclamation point on this. One of the key disruptions from COVID-19 was indeed supply chain. Here, I think for the first time, Susan, we started to look at geography as a risk. Geopolitical risk has been known for quite some time, but with the COVID-19, we have the swaths of the world that were unavailable to us because of the

Training presents an opportunity to not only educate workers, but also inspire their growth. But how can you do that in a way that feels energizing rather than exhausting? On this episode of the Principled Podcast, LRN Learning Manager Leah Hodge explores how to create engaging training with Rachel Donley, the Head of Learning & Performance Enablement for the KFC US market, a division of Yum! Brands. Listen in as the two talk about KFC’s Shift Supervisor training program, which has been receiving lots of industry recognition—winning gold at this year’s Brandon Hall Awards and being selected as a finalist for the Learning Technologies Awards—and improving leadership capability across the KFC US system of restaurants.     Featured guest: Rachel Donley Rachel Donley is a learning leader, instructional designer, gamification proponent, and strategic business partner. With 13 years of experience in the learning industry and 22 years of experience in the retail and food service industries, Rachel’s learning solutions have earned eight Brandon Hall awards. She was named a 30 under 30 Learning Leader in the inaugural Learning 2010 program and awarded the Brandon Hall Rising Star Award in 2017. Rachel holds a Master of Education in learning design from Bowling Green State University in Ohio and currently leads a team of seven to deliver learning and performance solutions to KFC’s 4100 US-based restaurants.   Featured host: Leah Hodge Leah Hodge brings more than 17 years of instructional design experience to the corporate learning and development space. As a learning manager and expert in strategic partnerships at LRN, she fosters relationships with clients to analyze their training needs with an eye on elevating the learner experience. She is passionate about designing and implementing creative bespoke solutions that get learners excited about their development, taking them on a journey beyond just checking-the-box completion—including blended learning, gamification, video and animation, and onboarding learner journeys.    Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace changemakers. Leah Hodge: Training presents an opportunity to not only educate workers, but also inspire their growth. But how can you do that in a way that feels energizing rather than exhausting? Hello and welcome to another episode of LRN's Principled Podcast. I'm your host, Leah Hodge, learning manager here at LRN. And today I'm joined by Rachel Donley, the head of learning and performance enablement for the KFC US market, a division of Yum! Brands. We're going to be talking about KFC's Shift Supervisor Training program, a project that we worked on together. And the whole program has been receiving lots of industry recognition, winning gold at this year's Brandon Hall Awards and being selected as a finalist for the Learning Technologies Awards. More importantly, the program has improved capability across KFC and their numerous franchises, setting the foundation for a new global best practice. Rachel, thanks for coming on the Principled Podcast today. I know there are lessons for others here and I'm excited to share your story. Rachel Donley: Awesome. Thank you for having me. Leah Hodge: Great. First question, for those who aren't familiar with this KFC story, let's start at the beginning. What were the business needs supporting this training? Rachel Donley: Yeah, thank you. Great question and I think it's really important to start out by understanding a little bit more about the shift supervisor role at KFC. Now, this is our entry level management role for the restaurants and a majority of higher level restaurant managers get promoted from within, from the supervisor role. So this junior hourly manager not only leads the teams during each shift, but they're in charge of everything that happens in the restaurant, including guest concerns, overseeing guest service and really culture, the team member experience. They really set the tone and really impact the culture on each shift in the restaurant. So this shift supervisor role really sets the foundation for KFC's management skillsets and capabilities throughout not only this role but for all future roles these shifts may be promoted into. So knowing that overview and background about what we're trying to accomplish for these roles in general, there was really a few other things that drove us to tackle and go after this training curriculum. The one was we simply needed a new one. Prior to this training rolling out, the only KFC corporate-provided training for shift supervisors was a very outdated, lengthy, really like old-school, 30 plus minute e-learning curriculum. And so there wasn't a lot of real-world application. And so it was very important and very needed that we updated this content so that not only it was more relevant, but it was also fits the modern learner. So I think that's the second piece and business need that we had here. Was to really look at our shift supervisor population today and say, "What does our shift supervisor demographics, generations, and the current industry across our restaurants, what do they really need? What does our modern learner need?" Some of that is based on research just across the board for current modern learners across any industry. And then some of that was really specific to the restaurant setting and really needing to grab their attention quickly, making sure that we're flexible, that we're mobile so that we can make sure that this shift supervisor role that gets pulled in many different directions when they're in the restaurant, also has a way to learn that fits what their everyday experience is in the restaurant and it makes it easier for them to learn as well. We also had a need with this training and one of our goals was to create consistency across our different restaurants. Because the older LMS 20, 30-minute e-learning courses were so outdated, KFC did not mandate that anyone was taking it. And this really resulted in a very inconsistent training and skillset building experience across our systems. A lot of restaurants or larger franchisees had created their own shift supervisor training programs to fill that gap, but some of the smaller organizations or some of the ones without those resources really didn't have a lot of training available. Now at some of our smaller organizations and restaurants, they may not have the resources or the necessarily ability to be able to craft their own training programs to fill the gap. And so again, this was driving a really inconsistent capability across our shift supervisor population. So one of the goals with this was not only updating, meeting the current learners where they're at, but also making sure that we were really level setting those foundational skillsets, behaviors and core competencies for shift supervisors across the entire US system. Regardless of which restaurant you're at, every shift would receive the same basic set of skills to make sure that they can be successful in role. And then I think the last thing is just like with any other training that we provide at KFC US, we also want to make sure that we're looking at business metrics and are we making a positive impact on the things that we would expect this learning to help drive? And so for shift supervisor, because they touch so much of our restaurants and so many of the pieces of our operations, we're really looking at how is this increasing like team member and restaurant engagement and culture? How is this increasing worker performance across different guest metrics and what's that meaning from a culture turnover and people perspective? Leah Hodge: Thanks for that Rachel. We really had a lot of goals to achieve with this training and I think we achieved that definitely. And so what I'd like to do now is dig into those design principles that were behind the Shift Supervisor Training. And I love... I'm biased. I love that the one outcome we had was that simulated game. Can you talk about how KFC chose that format? Rachel Donley: Yeah, absolutely. That's my favorite part as well. I think games and simulations in general just allow us to provide a level of behavioral practice that really isn't...  can't happen and it needs other type of like LMS delivered learning context. If anyone's familiar with the KFC US system, we're across the entire country, different time zones, close to 4,000 restaurants, and we just don't have necessarily the setup to deliver some kind of simulated experience and hands on, a face to face across the system. So when we're thinking about delivering something that's scalable and can be taken at any time by anyone in any time zone, we're really looking at something that's through the LMS and really games and simulations let us get as close to the learner environment as possible and really simulate assessing and letting the learner practice what they've learned in a safe and controlled environment. Now, we'll never specifically match an exact restaurant set up layout or experience in the game in a simulation, but we got really, really, really close. And this is so important, we all know from a learning transfer perspective, it's really important to make the learning and have them apply what they learned as close to the real world as possible. And I think that it just cannot be understated how much games and simulations can really be a force to seed what people have learned, start to apply it before they get into an environment, well, that has a lot going on. And especially if you think about shift supervisors, they're managers, they're leading a team, they're leading guest experience. We would much rather at KFC US, w

In September, the Department of Justice Fraud Section announced a new policy direction on corporate misconduct, clearly stating that personal accountability for employees, executives, and directors was their number one priority. The revised DOJ policy clearly states that an organization’s compensation and benefits program must be aligned to its values and ethical culture. So, what does this mean for compliance? In this episode of the Principled Podcast, host Susan Divers discusses how to implement a meaningful performance management system that meets DOJ objectives with Stephanie Ragan, a Certified Compliance and Ethics Professional (recently of SOFEC) and now solo practitioner after 14 years as a compliance specialist and manager in the oil and gas industry.    Featured guest: Stephanie Ragan As an experienced, well-rounded compliance and ethics specialist, Stephanie has recently struck out on her own by launching Ragan Export Compliance, a consulting company focused on providing services and guidance for regulatory compliance. A subject matter expert in trade compliance for the past 10 years, she holds both a Masters of Science in Regulatory Trade Compliance and a degree in International Trade Management. Her credentials include special certifications as a Certified United States Export Compliance Officer (CUSECO), a Certified Compliance & Ethics Professional (CCEP) and an FCPA Expert (FCPA Blog).With a passion for developing efficient, integrated and automated compliance systems and programs, Stephanie’s philosophy is that the intentional integration of compliance and ethics elements within an organization is at the core of every successful business model; and through making compliance accessible and approachable to all stakeholders, the value of a company’s culture is significantly increased.   Featured host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years’ accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.  Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.    Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: Last September, the Department of Justice Fraud Section announced a new policy direction on corporate misconduct. And they clearly stated that personal accountability for employees, executives, and directors was the department's number one priority. And as part of that, the revised policy that DAG, Lisa Monaco put out that day makes clear that an organization's compensation and benefits program must be aligned to its values and ethical culture. That means that positive behavior, for example, turning down a tainted business opportunity should be an essential factor in evaluating performance. And that there should be financial penalties, real financial penalties for misconduct. So what does that mean for compliance professionals? Hello, and welcome to another episode of LRN's DAG, Lisa Monaco. I'm your host, Susan Divers, director of thought leadership and best practices at LRN. Today I'm joined by Stephanie Ragan, a certified compliance and ethics professional, and most recently of Sofec, an oil and gas provider that's global in its operations. Stephanie has just left Sofec and is now consulting on her own after 14 years of a compliance specialist and a manager in the oil and gas industry. We're going to be talking about implementing a meaningful performance management system that meets DOJ objectives and how you go about that. Stephanie, thanks for joining me on Principled Podcast. Stephanie Ragan: Thanks for having me, Susan. Susan Divers: It's my pleasure. Interestingly, one of the questions we ask in LRN's annual program effectiveness survey is about organizations using ethical behavior as a significant factor in compensation, bonuses, hiring and promotion. And last year 69% of the over, I think it was about 1200 ENC programs that we surveyed, indicated that they required that an employee's ethical behavior be evaluated as part of their annual performance review. And we found that top rated programs were much more likely with 88% including such criteria. But Stephanie, as you know, with all things compliance, the devil is in the details. So I'd really like to hear about how you implemented your program that does just that at Sofec. And I'm sure our listeners would love to profit from your experience and your wisdom on this subject. So let's start at the beginning, how did you start this initiative or how did it start and how did you get support for it? Stephanie Ragan: Well, sure. So coming from a company like Sofec, we just celebrated our 50th year and we have a lot of mature programs and some that are still coming along. And our compliance program was one of our newer initiatives. We started it in about 2011. And it was interesting to see that when we formalized that department and all of our programs, policies, everything that helped sustain it, there was a need to measure it against other overhead type departments like HR, HSE and quality. So looking toward those types of departments for direction to see how we could measure effectiveness of programs and tie that back to our professional performance goal setting efforts that we do on an annual basis was a challenge for us. And we decided that as the new kid on the block, we could look at what worked for everybody and what didn't. And we decided that it would be necessary to look at what weight we needed to hold within the organization for each of our compliance initiatives. So for a starting point for our listeners, I would suggest that you look at the way your organizations measure performance. And if there is already an existing HSSEQ component or HR component, that you should also be including a compliance and ethics representation. And that should be a key area of focus for your personnel to align with your company culture and your company code and business operations. Susan Divers: That makes a great deal of sense. And I want to pick up on one thing you said in particular, which is that the ENC program needs to have equal status and weight with other similar programs, whether it's HR or audit or security or health and safety. And that's actually in the 2020 guidance from the Department of Justice as well. Because one of the questions prosecutors will ask or are told to ask companies accused of misconduct is, "Does your ENC program have equal status and resources?" So the approach you took fits very nicely with that. Let's talk about how you actually went about it. How did you enlist support? How long did it take? And what did you do in the end to get it up and running? Stephanie Ragan: Well, you know it takes a village to have any kind of success. And our compliance and ethics global team really took on this call to bring compliance and ethics to the forefront, it having an equal say in the performance measurements that we do in the company. And we were able to within the last few years, convince our management that along with performance measurement, which was a key area of concern, we needed to have regular meetings, at least an annual meeting, to be able to confer as a team globally and to discuss ideas, work on program development and get training initiatives ironed out. Kind of plan out our year as a whole so that globally we could have a cohesive plan that aligned everyone, didn't leave anyone behind from a planning standpoint for all of our entities, and made sure all personnel were covered by local compliance and ethics designees that could administrate and cover those programs as we rolled them out. So this was very well taken on. And again, we leaned b

What you'll learn in this podcast episode Guidance from the US Department of Justice, particularly the recent 2020 memorandum, stresses that a company’s compliance program must reflect and evolve with its risks—and should not be a snapshot or on cruise control. But in assessing those risks, it’s helpful to see what other companies in the same area or circumstances have done to meet them. Collective action and coordination can be very useful in dealing with common risks. So, when is benchmarking and a collective approach to risk helpful? And when can it backfire? In this episode of the Principled Podcast, LRN Director of Advisory Services Emily Miner continues the conversation from Episode 6 about benchmarking with her colleague Susan Divers. Listen in as the two discuss the benefits and limitations of benchmarking, and how organizations can ensure they benchmark their E&C programs effectively.    Featured guest: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years’ accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.  Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.  Featured Host: Emily Miner Emily Miner is a director of LRN’s Ethics & Compliance Advisory services. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.   Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Emily Miner: Guidance from the US Department of Justice, particularly the recent 2020 memorandum, stresses that a company's compliance program must reflect and evolve with its risks and should not be a snapshot or on cruise control. But in assessing those risks, it's helpful to see what other companies in the same area or circumstances have done to meet them. Collective action and coordination can be very useful in dealing with common risks. So when is benchmarking and a collective approach to risk helpful, and when can it backfire? Hello, and welcome to another episode of LRN's Principled podcast. I'm your host, Emily Miner, director of Advisory Services at LRN. Today I'm continuing my conversation from episode six about benchmarking with my colleague Susan Divers, our director of Thought Leadership and Best practices. We're going to be talking about the benefits and the limitations of benchmarking and how organizations can ensure they benchmark their E&C programs effectively. Susan brings more than 30 years experience in both the legal and E&C spaces to this topic area with subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Susan, thanks for coming on the Principled podcast. Susan Divers: Oh, Emily, it's always nice to talk with you. Emily Miner: So Susan, before we get started, let's kind of define benchmarking and summarize the conversation that I had in our last podcast with our colleague Derek. So benchmarking means comparing what you do as an organization in this case to a usually large number of comparable organizations or individuals. And most often, this is done in a quantitative way, although there are also opportunities to benchmark qualitatively. And at LRN, we've been using benchmarks for a number of years now through our research reports. We've conducted major panel research on the role of ethical culture in an organization and in organization's risk of misconduct. So looking at how that varies across countries, across industries. We conduct every year research into ethics and compliance program effectiveness research that you lead and that you and I collaborate on. And we've been doing that for, oh gosh, coming up on, I don't know, maybe eight years now. That's been given us a insightful look into Ethics & Compliance Program best practices, and how they've evolved over time. We've also conducted research on codes of conduct, analyzing nearly 150 publicly listed codes of conduct from the top listed companies around the world and looking at similarities and differences and best practices in that space. But we have a brand new product at LRN that we're launching later this month that I know we're all really excited about called Catalyst Reveal, which is a platform that will, as it's name suggests, reveal insights to our clients about their ethics and compliance program, things like course level data training, data, employee sentiment, ethical culture. It will also give our clients the ability to see how their results along these metrics compare with other organizations in the LRN client universe. So looking at by industry, by company size, and a few other comparable filters. So with that exciting launch as our backdrop, I wanted to talk to you as an expert and a thought leader in this space about benchmarking compliance programs, when to do it, when not to do it, et cetera. So let me turn it over to you, Susan, and let's start with the benefits. What are the benefits of benchmarking in ethics and compliance program? Susan Divers: Sure, Emily, I'd be happy to talk about that. In thinking about this topic, there are really three really good functions that benchmarking is appropriate for. And then there are some where it's not so appropriate and we can talk about all of that. But starting with what it's very appropriate for, the first is if you're setting up a program, you need to figure out kind of what are the basics that you need to do at the outset. And it can be very helpful particularly if it's a new program, and it usually is if it's setting it up to be able to say your management, "We have to have a code. We have to have policies. We have to have audit. And we have to have training" and those are kind of the four basic pillars and being able to make that case. That's very basic, but it can be very helpful in terms of people who are struggling to get started in what we all know is a really complicated area. So that's kind of the first setting where benchmarking I think can be very helpful. And then the second is you've got your program and you're up and going. Now, no two companies are alike, no two industries are alike, and I can get into that a little bit later, but it's helpful to know if you're mainstream or not. Like for example, our Ethical Pulse Culture check lets you sort of get an idea from a short questionnaire embedded in our platform in Reveal whether your culture is really out of whack or pretty much along the same lines as mainstream. And again, that's really helpful because it can show you an area where you're maybe excelling and it's good to take credit for that and scale it, or it can show you an area where you're deficient and it

What you'll learn in this podcast episode Over the last few years, federal regulators have provided detailed guidance on what they expect to see in E&C programs when it comes to misconduct inquiries or investigations. What do these recent reports, policies, and guidance mean for compliance professionals? In this episode of the Principled Podcast, LRN Director of Thought Leadership and Best Practices Susan Divers is joined by Jon Drimmer, a partner at the law firm Paul Hastings. Listen in as the two discuss the recent guidance from the US Department of Justice as well as DOJ policy impacting corporate compliance programs and ethical culture.      Featured guest: Jon Drimmer Jonathan C. Drimmer is a partner in the Investigations and White Collar Defense practice and is based in the Washington, D.C. office of Paul Hastings. He resolves complex cross-border problems with the benefit of having sat in every chair at the table: senior legal officer for a global 500 company, federal prosecutor, and seasoned advocate. He is a recognized international expert on anti­corruption and business and human rights, and is a frequent speaker, author, and commentator on issues related to both topics. Before joining Paul Hastings, he was Deputy General Counsel and Chief Compliance Officer of Barrick Gold, one of the world’s largest mining companies, with operations on five continents. The compliance program he built at Barrick has served as an industry standard, and elements of it have largely been duplicated by numerous other companies inside and outside of the extractive sector. Mr. Drimmer has directed hundreds of investigations around the world related to anti-corruption, human rights, AML and export controls, tax controversies, environmental incidents, public disclosures, fatalities and health and safety injuries, sexual harassment and discrimination, and other areas. He has represented companies and individuals in numerous government enforcement proceedings in the U.S. and overseas, in relation to FCPA and bribery claims, human rights issues, and a wide array of other matters. He has participated in dozens of major disputes in the U.S., Canada, and abroad, including transnational torts, anti-corruption claims, environmental cases, international arbitrations, tax disputes, construction claims, and land controversies. He previously served in the Justice Department as Deputy Director of the Criminal Division’s Office of Special Investigations, where he led cross-border investigations, first-chaired numerous prosecutions, and argued federal appeals. He was a partner at an Am Law 100 law firm in Washington, D.C., a former Bristow Fellow in the Office of the U.S. Solicitor General, and a judicial clerk on the U.S. Court of Appeals for the Ninth Circuit. Mr. Drimmer served on the board of directors of the Voluntary Principles on Security and Human Rights Initiative from 2012-2014, and again from 2015-2017. He served on the board of TRACE International from 2012 until 2018, and currently sits on the board of the TRACE Foundation. He has also taught international law courses at Georgetown University Law Center for nearly 20 years.   Featured Host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years’ accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.  Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.    Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers:  Good afternoon. From time to time, but particularly in the last few years, federal regulators have provided detailed guidance on what they expect to see in ethics and compliance programs when companies present them as a defense to misconduct inquiries or investigations. What do the recent flurry of reports, policies and guidance mean for compliance professionals? How should they be applied to improve E and C programs? Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, director of thought leadership and best practices at LRN. And today, I'm joined by Jon Drimmer, a partner at the international law firm of Paul Hastings. We're going to talk about the recent DOJ guidance and policy impacting corporate compliance programs and ethical culture, and hopefully help everyone understand what it is and how they should apply it to their programs. Jon is a real expert, as well as a friend in this space. He has the unusual distinction of serving in three of the principal seats that affect ethics and compliance, once as a federal prosecutor at DOJ, another time as a chief ethics and compliance officer and deputy general council for a large mining company, and now as an ethics and compliance advocate with a leading law firm. Jon, thanks so much for joining me at Principled Podcast. Jon Drimmer: Thanks, Susan. It's great to be with you. Susan Divers: Super. Well, let's jump right in. Last week, we saw a new policy come out of the Department of Justice that both Lisa Monaco and also Ken Polite have talked about with great emphasis. We've also seen the report come out of the sentencing commission about their 30 years of accomplishments. And we've also seen some major guidance in the last two years. Can you put it in perspective for us and talk about how it fits together, and how they interplay. And then we can jump in and start figuring out what they mean. Jon Drimmer: Yeah. No, happy to do it. So let me take each one in sequence. So what we saw come down from the deputy attorney general was a new policy memo. And in essence, what that means is policies are, they are the rules that apply to federal prosecutors and prosecuting entities around the country. They are the standards that are going to be applied. Guidance, which is something that we see come out in a number of different ways through formal guidance as well as through statements and speeches and other informal approaches, this is basically how those rules are interpreted, how prosecutors should be thinking about the application of those policies as they're applied to any given circumstance. And then finally, reports, and you mentioned the sentencing commission's 30 year look back, those are more general. And they do tend to come out for transparency purpose, they're often retrospective, like the sentencing commission report. But they generally talk about how these rules have been applied. So policies are the rules, the guidance effectively aids in their interpretation, and the reports generally are a bit of a look back as to how they have been applied to date. Susan Divers: That's really helpful. It really helps me put all of those in perspective. Talk a little bit more than about the policies and the guidance. Are they mandatory? Are they voluntary? Jon Drimmer: Well, for prosecutors, they're mandatory. So when you look at the policies, this is effectively how prosecutors are to approach any given situation. It is a directive to them in terms of how it is they should go about doing their jobs. And I'll tell you it's critical. It's critical for chief compliance officers to understand those types of initiatives, those types of emphases. It's critical to prosecutors as well, as they get that direction in terms of what they should be focusing on. So really, it's a very important part of the process and helping to shape how investigations are run and scoped from the government's end, and what can be expected on the company side as well for chief compliance officers. Susan Divers: But it's not technically a rule, if I'm correct. But it sounds like you strongly recommend that ethics and compliance professionals pay great attention t

What you'll learn in this podcast episode How do you know if your ethics and compliance program is successful? How are you capturing data and comparing it to industry benchmarks, or tracking your own company’s trends over time? In this episode of LRN’s Principled Podcast host Emily Miner, director of Advisory Services at LRN, talks about benchmarking E&C data with her colleague Derek Clune, product manager of Data & Analytics. Listen in as the two explore how benchmarking practices come to life and the role AI plays in LRN's new Catalyst Reveal solution.   Featured guest: Derek Clune Derek Clune has been working in the ethics and compliance space for over 5 years with an emphasis on data and analytics. As a Product Manager at LRN, Derek is responsible for the vision of LRN’s new data and analytics platform; Catalyst Reveal. His main goal is to provide E&C professionals with more actionable data to understand their E&C program effectiveness better. Derek’s team works to create products that offer best-in-class prescriptive interventions to improve E&C programs and ease the administrative burden.   Featured Host: Emily Miner Emily Miner is a director of LRN’s Ethics & Compliance Advisory services. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.   Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Emily Miner: Gone are the days of checklists, ethics, and compliance programs where one simply goes down a list of program features and elements. Now, regulators, employees, customers, leaders are asking, are our ethics and compliance programs effective? Are they successful? Well, how do you know? Hello, and welcome to another episode of LRNs Principled Podcast. I'm your host, Emily Miner, director at LRN. And today I'm joined by my colleague Derek Clune, product manager of Data and Analytics at LRN. We are going to be talking about ethics and compliance benchmarking and how organizations can track their own trends over time, as well as compare themselves to industry peers. We're going to talk about how all of this data comes together in technology environments like LRNs new Catalyst Reveal Solution which is launching soon. Derek is a real expert in this space. He's been working in that data and analytics vertical at LRN for a number of years, and is a key architect behind our product innovation and incorporating the insights of our industry collaborators at major corporations around the world. Derek, thanks so much for joining me on the Principled Podcast. Derek Clune: Absolutely, Emily. Pleasure to be here. Emily Miner: So before we get in, maybe just some definitions and level setting. So what is benchmarking? The way that we think about it, it typically means comparing what you do as an organization to a number of comparable organizations or individuals. And usually this is done in a quantitative way, so a more kind of a numeric databased way as opposed to a qualitative way. And benchmarking is helpful just for comparative purposes. And it can also help to identify best practices in the industry. And best practices referring to those behaviors, those practices systems, which some sort of research shows that the very top firms use in a way maybe beyond or to a greater degree than other organizations. So why do organizations benchmark or want to benchmark? Derek, I know that you have a lot of conversations with our client partners around their benchmarking requests and their needs. But sort of as an overarching point, why are companies interested in benchmarking? What's the value to them? Derek Clune: Yeah, I think there's a number of reasons why we see it. In my conversations with our partners, obviously regulators are looking at ethics and compliance programs with much higher scrutiny than they ever have. And so organizations want better visibility into the wider space, whether that's how their ethics and compliance program measures against others within their industry, whether that's how it measures against others from an employee size or geographic footprint. So organizations use really two sets of benchmarks, internal company benchmarks. Their own data and organizational assessments and benchmarking those quarterly year over year to measure their own program. But also they want a broader audience to compare themselves to, to really see where they... For lack of a better term, rank within the pack so to speak. And so a lot of this we see is all around measuring ethics and compliance program effectiveness. How do I know my program's effective? I have the parts and the components, the codes of conduct, the policies, the disclosure certifications, but how do I know that those are effective? And we're seeing more and more that data is being used as a key component in that measurement of program effectiveness. Emily Miner: Yeah, I'm reflecting on some conversations that I've had with our partners where they've said, our calls to our hotline are X percent. Is that good? When we look at our... We can collect data on ourselves and measure it and certainly that's sort of where organizations have been heading for a while. This increased data collection and analysis. But sometimes doing that in a vacuum, you're sort of left wondering, okay, well, the number is four, is that good? Should it be five? Should it be one? Should it be 20? What does this mean? And I think that's where that comparison is helpful because you used the term kind of broadening the pool or broadening the lens. I don't remember exactly what you said, but that idea of broadening your view finder. And that's where I think the strive for this desire for being able to benchmark and compare a large place of where it comes from. And just also as humans, we like to compare ourselves to others in so many parts of our life. So there's maybe a human nature component to it too. Derek Clune: Yeah. No, absolutely, you took the words right out of my mouth. None of these organizations while they all are unique operate in a vacuum. And so they need to have some sort of comparison just to know that they're below, above or equal to a number because we know the regulators don't give specifics. So the next best thing that we have really is this benchmarking tool of, in our case all of the LRN partners, which over 2000 partners in a number of different industries, Fortune 500, et cetera. Emily Miner: Yeah. And so Derek, I know that you partake in a lot of voice of the customer type conversations, and you are the recipient of a lot of requests for information from others within our organization. What are some of the top requests or data questions that you hear from our partners? You talked about wanting to measure program effectiveness, how are people thinking about program effectiveness? What do they want to measure? What do they currently have versus what don't they have but they want it? What are some of the general themes? Derek Clune: At a high level we know that all of these questions typically start with a risk assessment. A company will do a risk assessment from a third party to get at maybe their blind spots or to tell them some things that they already know. And so in most cases that serves as the initial roadmap of different topics to consider around benchmarking around these data questions. And so from there we see organizations typically focused on the course data. That's the most popular one. We're rolling out mandatory training, how are my employees performing on that training? It has some sort of test in it, are my employees performing better or worse than I expected or right on par with what the requirements are? And within that there's a lot of different sub context. So is a particular business unit outperforming or underperforming based on the average or the median?    Is there a regional confusion around a question? So I would say the initial focus that people immediately go to is the mandatory training that is being assigned and the course performance metrics I'll say, how employees are performing within those courses. There are a lot of tertiary components that are critical to measuring program effectiveness. What we see also is culture being a critical component of ethics and compliance. And larger initiatives at an organization at measuring that overall learner sentiment of the communications and the courses that are being rolled out to the learners. So not only are we looking at the performance aspect of those but also the sentiment and learner feedback of what they think. All of those kind of surveys where you're getting additional feedback from employees is anot

What you'll learn in this podcast episode “Thirty years of innovation and influence” is the subtitle of the recent report issued by the United States Sentencing Commission. But what does that really mean in the context of the organizational sentencing guidelines? In this episode of LRN’s Principled Podcast, Eric Morehead, LRN Director of Advisory Services Solutions, is joined by one of the report’s authors: Kathleen Grilli, the General Counsel for the US Sentencing Commission. Listen in as the two discuss how the commission impacts business leaders and the creation of compliance programs.    Read LRN’s takeaways from the report here.  Principled Podcast Show Notes coming soon   Featured guest: Kathleen Grilli Kathleen Cooper Grilli is the General Counsel for the United States Sentencing Commission, having been appointed to the position on October 7, 2013. Ms. Grilli has been on the staff of the Commission since 2003, serving as an assistant general counsel from 2003-2007 and deputy general counsel from 2007-2013. As the General Counsel, Ms. Grill provides legal advice to the Commissioners on sentencing issues and other matters relating to the operation of the Commission. Ms. Grilli is the agency’s Ethics Officer and has conducted training on white collar crime and the organizational guidelines at numerous training events.Prior to working for the Sentencing Commission, Ms. Grilli was with the Office of Staff Counsel for the Fourth Circuit Court of Appeals. Before relocating to Virginia, Ms. Grilli was a partner in a small firm in Fort Lauderdale, Florida, handling civil and criminal litigation. Her previous work experience includes serving as an Assistant Federal Public Defender in the Southern District of Florida and as an associate at Akerman, Senterfitt and Edison, handling commercial litigation. Ms. Grilli is a member of the Bars of Florida and Virginia. She received a Bachelor of Arts in International Relations, with honors, from Florida International University. She graduated cum laude from the University of Miami School of Law.   Featured Host: Eric Morehead Eric Morehead is a member of LRN’s Advisory Services team and has over 20 years’ experience working with organizations seeking to address compliance issues and build effective compliance and ethics programs. Eric conducts program assessments and examines specific compliance risks, he drafts compliance policies and codes of conduct, works with organizations to build and improve their compliance processes and tools, and provides live training for Boards of Directors, executives, managers and employees.    Eric ran his own consultancy for six years where he advised clients on compliance program enhancements and assisted in creating effective compliance solutions.  Eric was formally the Head of Advisory Services for NYSE Governance Services, a leading compliance training organization, where he was responsible for all aspects of NYSE Governance Services’ compliance consulting arm. Prior to joining NYSE, Eric was an Assistant General Counsel of the United States Sentencing Commission in Washington, DC. Eric served as the chair of the policy team that amended the Organizational Sentencing Guidelines in 2010. Eric also spent nearly a decade as a litigation attorney in Houston, Texas where he focused on white-collar and regulatory cases and represented clients at trial and before various agencies including SEC, OSHA and CFTC.     Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Eric Morehead: 30 Years of Innovation and Influence is the subtitle of the recent report issued by the United States Sentencing Commission, but what does that really mean in the context of the organizational sentencing guidelines? Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host today, Eric Morehead, Director of Advisory Service Solutions at LRN. Today, Kathleen Grilli, the General Counsel of the United States Sentencing Commission is joining us. She's one of the authors of this recent report, and we're going to be talking about how the commission impacts business leaders and the creation of compliance programs across the world. Kathleen is a real expert in this space and is a guest of ours last season where we talked about the seven hallmarks of an effective ethics and compliance program enshrined in the US Sentencing Commission's federal sentencing guidelines. Kathleen Grilli, thanks for joining us again on the Principled Podcast. Kathleen Grilli: Well, thanks for inviting me, Eric. I appreciate it. Eric Morehead: The commission just released this new report, The Organizational Sentencing Guidelines: 30 Years of Innovation and Influence. Even after more than 30 years, there are still, I think, at least from my perspective, many people who, when they start their career in compliance, are confused a little bit about why the Sentencing Commission is involved in corporate compliance. Can you talk just a little bit about how the US Sentencing Commission came to assume the role it has regarding compliance standards? Kathleen Grilli: Sure. You say that people in compliance are confused about it, but the truth is, even in the criminal justice arena where the commission operates... Our guidelines are used in federal courts for sentencing organizations and offenders. Even in that arena, there's not really widespread knowledge about Chapter 8 and the hallmarks for an effective compliance and ethics program. That's because there aren't a lot of organizational cases sentenced every year. But the reason the commission got into the business of corporate compliance has to do with its statutory mission. The commission was created in 1984 through a bipartisan piece of legislation called the Sentencing Reform Act, and that act did a couple of things as it related to sentencing of organizations. It provided that organizations could be sentenced to a term of probation, sentenced by way of a fine, and it required that at least one of those be imposed. This was something new. It also subjected organizations to orders of criminal forfeiture, meaning the proceeds of the criminal activity could be taken from them, order of notice to victims, and orders of restitution. That act also created the commission, which is a bipartisan agency and tasked the commission with developing guidelines for use in criminal cases for sentencing. It told us what the purposes of sentencing are, which is just punishment, deterrence, protection of the public, and rehabilitation of the offender. The commission had to decide what to do for sentencing of an organization. Obviously, you cannot put an organization in prison. Unlike individual offenders where sentencing ranges in terms of incarceration are something of the norm, you had to figure out what to do to sentence organizations. With an organization, as we know, the bottom line is they're in business to make money. In developing the organizational guidelines, the commission came up with its notion that it should use fines to incentivize self-policing. It would punish organizations who were not self-policing or not trying to prevent a crime or commit the offense with certain aggravating factors more severely than those who were trying to prevent and detect crime. That's how we got into the business of corporate compliance. Eric Morehead: Yeah. And it is interesting that the original writ was from the statute that you examine this. Can you talk a little bit about how the commission got specifically to those hallmarks, those programmatic pieces that we talked about a little bit on our last podcast a while ago? What was the process for the commission to get to those standards, those specific compliance pieces of the puzzle, if you will? Kathleen Grilli: The commission started its work in 1986 on organizational guidelines with a public hearing at which it received testimony from a variety of witnesses across various different wakes of the world: academics, people in business, government agencies, and the like. Over about a five-year period, because as I said, the Commission started its business in 1986 and didn't actually promulgate the organizational guidelines until 1991. During that period of time, there were numerous public hearings attended by a wide range of witnesses from different areas of the law, academics, government agencies, business owners, representatives of just different industries, and the like. The Commission had these hearings, they heard testimony, the Commission went back and developed drafts with proposals for how organizations would be sentenced. They published those drafts. The process of publishing is really a solicitation for public comment, so they got public comment on the drafts. This went on for a good period of time. In the meantime, the Commission was doing research. We had academics writing proposals and giving us ideas on how to implement the purposes of sentencing, which again, as I said, were just punishment, deterrents, protection of the public, and rehabilitation. Eventually, it came back to how does an organization get in trouble to begin with? An organization doesn't act alone. We have this theory in the law called vicarious liability where an organization is held responsible for the acts of its agents, meaning its employees. If the employees are the bad actors, everyone finally came to the conclusion that the best way to incentivize or prevent corporate crime was for the organization itself to self-police and to direct its employees and talk about what is and is not appropriate. That's how we ended up with compliance standards. At the time that they started all this work, compliance and ethic

What you'll learn in this podcast episode Most of us have heard the phrase, “If you see something, say something.” But what does that look like when someone witnesses bad behavior in the workplace? How can companies help their employees be active bystanders in the face of misconduct? In this episode, LRN colleagues Felicity Duncan, senior instructional designer, and Kristen Motzer, learning director, share their expertise on bystander intervention training and how organizations can effectively give employees the knowledge and skills they need to step in and help their coworkers. Listen in as the two share insights from their latest course development for the training library at LRN.   Principled Podcast Show Notes [1:22] - What does it mean to be a bystander, and why do organizations have bystander training? [3:05] - Unpacking the idea of a “Speak up culture”. [3:40] - Why don’t people get involved when they see problems? [6:08] - How to train people to be active bystanders? [9:36] - Why are scenarios so important? [12:14] - How DEI relates to bystander intervention. [15:26] - How having a robust bystanding and speak up culture will benefit partners.   Featured guest: Kristen Motzer Kristen Motzer is an experienced leader in values-driven, empathetic behavior change. As Learning Director for the LRN Library she oversees course content development and online, blended, and facilitated learning experiences. She has expertise in human-centered learning design and has developed and managed education and learning programs at institutions such as NYU Langone Health, NeuroLeadership Insitute, Stanford University, Xavier University, and the Cleveland Clinic. Kristen holds a BA from Wright State University and an MA from Carnegie Mellon University and resides in Chicago.   Featured Host: Felicity Duncan Dr. Felicity Duncan believes that training and communication interventions have the power to transform behavior, including driving people toward more ethical treatment of those around them. Felicity graduated with a Ph.D. in Communication from the University of Pennsylvania. After teaching at the college level for several years, she transitioned to workplace education to have a bigger impact on working adults by providing them with the training they need to truly thrive in their roles. At LRN, she is focused on developing high-impact, behaviorally focused content for the LRN Library. Her most recent project saw her working with the Library team to create a powerful new DEI Program that includes not only LRN’s world-class Inspire courses but also a set of microlearning assets designed to support, reinforce, and guide behavior change.   Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Felicity Duncan: Most of us have heard the phrase, "If you see something, say something." But what does that actually look like when someone witnesses bad behavior in their workplace, like bullying or harassment? And how can companies help their employees be active bystanders in the face of misconduct? Hello, and welcome to another episode of LRN's Principled podcast. I'm your host, Felicity Duncan, Senior Instructional Designer here at LRN. And today, I'm joined by my colleague Kristen Motzer, the Learning Director of LRN's Library Course Content. Kristen has over 20 years of experience in technology supported learning and development, and I am a PhD with a decade of experience working in both academic and professional training environments. Kristen, thanks for joining me on today's Principled podcast. So, let's start with the basics. What does it mean to be a bystander and why do organizations have bystander training? Can you explain the sort of core idea here? Kristen Motzer: Sure. A bystander is someone who witnesses misconduct but isn't directly involved in the situation. So, they see something happening, but they're not actually a part of it. So, being an active bystander is about doing something as opposed to just standing by when you see someone being harassed or bullied or abused. And there's actually a lot of research showing that bystander intervention can have a major impact. When bystanders intervene in situations in the right way, they can stop abuse in its tracks, support victims, and really make perpetrators reevaluate their behavior. However, very often bystanders witness abuse and harassment and say nothing. That's why we need active bystander training that equips people with the tools they need to intervene successfully when they see something wrong. So, recently we've seen a lot of interest in bystander training from our partners, and Chicago now has an requirement for our long bystander of training for employees in Chicago. But really beyond that, there's a recognition that engaging your workforce to do something, to fight back, to say this is not behavior that we want to have in our workplace can be really powerful. And it's creating a speak up culture. Felicity Duncan: So, tell me a little bit more about this idea of the speak up culture. What do we mean by that? Kristen Motzer: So, it's creating an environment where people feel safe to be able to speak up. Of course, speaking up is a little bit scary. You don't know what's going to happen. There could be retaliation, things could change. The folks that usually eat lunch with might not want to eat lunch with you anymore. Things might change an environment that we spend a lot of time in at work. So, creating a safe space where there's an expectation that you see something that you don't want in your workplace culture, you're going to speak up and say something. Felicity Duncan: So, obviously acts of bystander intervention is really important. We really want this speak up culture that's going to help us build a better workplace environment. So, why don't people get involved when they see problems? Kristen Motzer: It's a great question, and it's really important to understand that it's not because people don't care. It's not that we're bad people at work or wherever we might be. It's that we're human. And intervening can be really difficult. Psychology has shown research from the 60s and onward that people have good intentions, and people tend to actually believe that if they saw something happening like harassment, discrimination, that they would get involved. But when it actually happens, that intention that they would get involved disappears and they just freeze up. And it's because of our fight, flight, freeze response kicking in. We're facing an unknown situation. We don't know how the people involved will react, and we're just scared of looking stupid, upsetting someone, getting into trouble, being embarrassed besides the possible outcomes like having some kind of retribution losing our job or our workplace friendships. So, from a biological and neuroscience perspective, our brains flood with stress hormones and react as though we're facing something like a bear, a really dangerous situation even though it's a social threat, not an actual bear, it can feel just as intense. So, when this happens, it's really hard for humans to overcome these instincts and get involved. So, we freeze. We try not to make eye contact, we put our heads down, try to hide, and if we're in a group, behavioral psychology research is found that it's even worse. So, when there's multiple people witnessing a situation, everyone's kind of expecting someone else is going to take action, and we sort of take the lead of kind of like group think. We take the lead from those around us, and if they're not doing anything, then we won't do anything. We have all these reasons why people don't intervene when they're bystanders. And Felicity, given these barriers, how do you train someone to be a bystander at work? I would love for you to take me through how you created the Inspire Active Bystander Training. Felicity Duncan: Well, luckily for us, the research that you mentioned earlier that talks about why bystanders don't intervene also gives us hope. It shows us how we can overcome those barriers to intervention. At what it really boils down to is being prepared, right? Being ready to get involved in these situations. But the truth is, it's a long road to get learners to that point. So, I'm going to walk you through what we did and why we think that works. So, we begin our training by acknowledging that this is hard. As you said, a lot of people assume that if they're in a bystander situation, that they're going to do the right thing, and then when it actually happens, they're unprepared for how scary it is, and for how strongly and viscerally they react to that fear, right? And so what we try to begin with is getting our learners to understand what to expect, right? We're really frank about the fact that it's going to be scary. Your palms are going to be sweaty, your heart is going to be pounding. You're going to be really afraid, all right? And telling them that feel the fear, but overcome it because that is not a reason not to intervene. It's just part of the experience. And so, in that way, we try to help prepare them for how it's actually going to be. What they're actually going to feel when a situation arises where they need to make some kind of intervention. Then what we do is we give learners some very practical strategies for how to intervene. And again, we're preparing them, right? We give them a literal list of step one, step two, step three, Here are four possible approaches to intervention. Here's how you would implement those approaches to intervention. So, it gets incredibly practical so that when learners are faced with these situations in the real world, they don't have

What you'll learn in this podcast episode A few weeks ago, the United States Sentencing Commission (USSC) issued a report titled The Organizational Sentencing Guidelines: Thirty Years of Innovation and Influence. The publication summarizes the history of Chapter Eight’s development and discusses the two substantive changes made to the elements of an effective compliance and ethics program. So, what does this mean for compliance professionals? In this episode of the Principled Podcast, host Jen Uner, Strategic Communications Director at LRN, talks about the guidelines with Eric Morehead, Director of Advisory Services at LRN. Listen in as the two discuss how these updates—and the wider USSC—impact corporate governance. The purpose of the U.S. Sentencing Commission is to study and develop sentencing policies for the federal courts. The Commission serves as an information resource for Congress, the executive, the courts, and the public on matters relating to federal crime and sentencing. Our episode today focuses on Chapter 8, which addresses organizational sentencing guidelines, not individual sentencing guidelines which is also a significant focus for the USSC.     Principled Podcast Show Notes [1:24] – Explanation of the new publication from the U.S. Sentencing Commission and why it matters. [6:42] - How the original standards have held up over the last 30 years. [7:51] - Eric outlines some of the highlights of the most recent publication. [12:53] - The real repercussions for organizations. [14:58] - The relationship of the Sentencing Commission with the DOJ and SEC. [18:33] - Steps organizations should take when crafting their own E&C programs. [21:43] - The role of company culture in determining how effective the program will be.   Featured guest: Eric Morehead Eric Morehead is a member of LRN’s Advisory Services team and has over 20 years of experience working with organizations seeking to address compliance issues and build effective compliance and ethics programs. Eric conducts program assessments and examines specific compliance risks, he drafts compliance policies and codes of conduct, works with organizations to build and improve their compliance processes and tools, and provides live training for Boards of Directors, executives, managers, and employees. Eric ran his own consultancy for six years where he advised clients on compliance program enhancements and assisted in creating effective compliance solutions. Eric was formally the Head of Advisory Services for NYSE Governance Services, a leading compliance training organization, where he was responsible for all aspects of NYSE Governance Services’ compliance consulting arm. Prior to joining NYSE, Eric was an Assistant General Counsel of the United States Sentencing Commission in Washington, DC. Eric served as the chair of the policy team that amended the Organizational Sentencing Guidelines in 2010. Eric also spent nearly a decade as a litigation attorney in Houston, Texas where he focused on white-collar and regulatory cases and represented clients at trial and before various agencies including SEC, OSHA and CFTC.       Featured Host: Jen Üner Jen Üner is the Strategic Communications Director for LRN, where she captains programs for both internal and external audiences. She has an insatiable curiosity and an overdeveloped sense of right and wrong which she challenges each day through her study of ethics, compliance, and the value of values-based behavior in corporate governance. Prior to joining LRN, Jen led marketing communications for innovative technology companies operating in Europe and the US, and for media and marketplaces in California. She has won recognition for her work in brand development and experiential design, earned placements in leading news publications, and hosted a closing bell ceremony of the NASDAQ in honor of the California fashion industry as founder of the LA Fashion Awards. Jen holds a B.A. degree from Claremont McKenna College.        Principled Podcast Transcript Intro:   Welcome to the Principled Podcast brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Jen Uner: A few weeks ago, the United States Sentencing Commission issued a report titled The Organizational Sentencing Guidelines: 30 Years of Innovation and Influence. The publication summarizes the history of Chapter Eight's development and discusses the two substantive changes made to the elements of an effective compliance and ethics program. Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Jen Uner, strategic communications director at LRN, and today, I'm joined by my colleague, Eric Morehead, director of advisory services solutions at LRN. We're going to be talking about the guidelines, and how it impacts corporate governance and what compliance professionals need to know. Eric Morehead is a real expert in the space as he once worked on these guidelines in a prior role at the US Sentencing Commission. He advises LRN clients now on these topics. Eric, thank you for coming on the Principled Podcast. Eric Morehead: Thanks, Jen. It's good to be here. Jen Uner: So hot off the press is this new publication from the US Sentencing Commission. Tell us about what it is, why it matters, and especially to owners of compliance programs at their organizations. Eric Morehead: Well, it's sort of a look back over the last 30 years. The Sentencing Guidelines for organizations were first promulgated and came into effect in 1991, so technically the 30th anniversary was last year, but the report has just come out now, and over those 30 years, there's been about 5,000 organizations that have been sentenced under the US Sentencing Guidelines. The Sentencing Commission and the Sentencing Guidelines have to do with federal sentencing, so either individuals or organizations who have been charged with a federal offense and find themselves in a federal district court, somewhere in the United States, and they either have pled guilty, or been found guilty by a jury, or found guilty by a judge after a bench trial, and now they're being sentenced. So when you sentence an individual, obviously, that can include a fine in restitution, but also time in a federal penitentiary. You can't jail an organization, but the Organizational Guidelines have put together over the last 30 years standards by which the judge can assess fines, restitution, and also order when necessary compliance reforms and implementation. Since you can't put the organization behind bars, you can however, put the organization on probation and require the organization to make some necessary reforms, if you will. So that's a kind of quick background of what the guidelines are for those of you who weren't sure, and why they matter to us, because the implementation of compliance standards is baked into any kind of probationary sentence or sentence that's handed down to an organization, or can be baked into, I should say. Jen Uner: And you have personal experience at the USSC. Eric Morehead: Yes, I worked at the Sentencing Commission from about 2007 to 2011, and during that period, there have been two amendments to the original guidelines that were first put out in 1991 for organizations. The first was in 2004, partly in response to Sarbanes-Oxley and the legislation that came out at that point around implementing reforms for organizations and their governance, but also there was back at the time in the early 2000s, a task force put together that the Sentencing Commission took some advice from. And so they made some amendments in 2004. The primary thing that happened in 2004 is that these compliance standards that are in the Sentencing Guidelines were put more front and center. They had been what are called application notes before, and they were actually promoted, if you will, to an actual textual listing in the guidelines. Just making them more prominent is really what it boiled down to. Also, putting a little further definition around the components of an effective program, training, governance and oversight, written standards, and procedures in place, reporting mechanisms, that we all know most organizations have an anonymous reporting mechanism, a hotline or helpline out there. That comes out of these standards that were first put together by the US Sentencing Commission. They were the first national standard in the United States anyway that suggested having a reporting mechanism, including with an anonymous option. Enforcement, discipline, and incentives often overlooked, but the Sentencing Guidelines have been talking about incentives for the past couple decades as well. And then in 2010 while I was there, the second amendment to the Organizational Sentencing Guidelines was undertaken, and that also strengthened that relationship between the governing authority of the organization, the board of directors, or whatever the oversight of a particular organization might be, because these guidelines affect not just public companies, but any kind of organization, so nonprofits, governmental agencies. Any kind of organizational structure is contemplated by the guidelines, and the 2010 amendments strengthened that relationship between the people actually responsible for the program and the governing authority of the organization, and also provided some incentives for organizations to come forward and to reform their programs. So those things have all happened over the years. Given the length of time that the Sentencing Guidelines have been in effect, now 30 years plus, to only have gone back and revisited them twice is not that significant. So they've been kind of bedrock standards that have existed and been well known. We often talk about them as the hallmar

What you'll learn in this podcast episode How are boards of directors of major companies coping in 2022 with the increasing expectations from so many stakeholders? How can directors equip themselves to meet oversight challenges and ensure that their companies do business in the right way? In this episode of the Principled Podcast, guest host Dr. Marsha Ershaghi Hames explores the critical role of boards in shaping ethical corporate culture with Diana Sands, an accomplished corporate leader who currently sits on the boards of SP Plus Corporation and PDC Energy. Listen in as the two discuss the evolving responsibilities and tools for today's boards, including guidance from the latest report from LRN and Tapestry Networks: Assessing Corporate Culture: A Practical Guide to Improving Board Oversight.   Principled Podcast Show Notes [2:15] – Diana Sand’s background and its impact on her board roles. [8:07] - The push for board culture refreshment and ESG priorities. [12:06] - Thoughts on changing attitudes toward board culture. [15:37] – Board needs for transparency, accountability, and communication. [18:34] - Navigating structural impediments and the Assessing Corporate Culture report.   Featured guest: Diana Sands Diana Sands brings over 30 years of business experience to her board and advisory roles having held senior executive finance and governance positions across multiple industries. Diana currently serves on the boards of SP+ (Nasdaq: SP), PDC Energy, Inc. (Nasdaq: PDCE), and National Philanthropic Trust (the largest independent provider of donor-advised funds). She is the Board Chair for Start Early, a non-profit champion for quality early learning. She is also an advisor to New Vista Acquisition Corp. and to Ethisphere (a global leader in defining and advancing the standards of ethical business practices). Diana retired from The Boeing Company in 2020 where she was an executive officer and Senior Vice President, at the Office of Internal Governance and Administration. Reporting to the CEO and to the audit committee, Diana oversaw a diverse team including ethics & investigations, compliance risk management, internal audit, security, and internal services. Previously, Diana held senior finance roles at Boeing including corporate controller where she signed and oversaw the development of the company’s financial statements, and head of investor relations where she was the primary management liaison with investors and industry analysts. She also led financial planning & analysis and worked in corporate treasury. Prior experiences include leading financial planning & reporting for General Motors Corporation and working at several companies in audit and product line finance positions. Diana has an MBA from Northwestern's Kellogg School of Management, and a BBA from the University of Michigan Ross Business School.   Featured Host: Dr. Marsha Ershaghi Hames Dr. Marsha Ershaghi Hames is a partner with Tapestry Networks and a leader of our corporate governance practice. She advises non-executive directors, C-suite executives, and in-house counsel on issues related to governance, culture transformation, board leadership, and stakeholder engagement. Prior to joining Tapestry, Marsha was a managing director of strategy and development at LRN, Inc. a global governance, risk and compliance firm. She specialized in the alignment of leaders and organizations for effective corporate governance and organizational culture transformation. Her view is that compliance is no longer merely a legal matter but a strategic and reputational priority.  Marsha has been interviewed and cited by the media including CNBC, CNN, Ethisphere, HR Magazine, Compliance Week, The FCPA Report, Entrepreneur.com, Chief Learning Officer, ATD Talent & Development, Corporate Counsel Magazine, the Society of Corporate Compliance and Ethics and more. She hosted the Principled Podcast, profiling the stories of some of the top transformational leaders in business. Marsha serves as an expert fellow on USC’s Neely Center for Ethical Leadership and Decision Making and on the advisory boards of LMH Strategies, Inc. an integrative supply chain advisory firm and Compliance.ai, a regulatory change management firm. Marsha holds an Ed.D. and MA from Pepperdine University. Her research was on the role of ethical leadership as an enabler of organizational culture change. Her BA is from the University of Southern California. She is a certified compliance and ethics professional.   Principled Podcast Transcript Intro: Welcome to the Principled Podcast brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Marsha Ershaghi Hames: How are boards of directors of major companies coping in 2022 with the increasing expectations from so many stakeholders? How are boards equipping themselves to meet the challenges of overseeing organizations? And how can directors ensure that their companies are doing the right things and doing business in the right way? Hello, and welcome to another episode of LRN's Principled Podcast, where we continue our conversations about the critical role of boards in shaping ethical corporate culture. I'm your guest host Marsha Ershaghi Hames, a partner at Tapestry Networks. And today, I'm joined by Diana Sands, an accomplished corporate leader who currently sits on the boards of SP Plus Corporation and PDC Energy. Today, we're going to talk about the evolving responsibilities of today's boards, many of which are outlined in the newest report, Assessing Corporate Culture, a report from LRN and Tapestry Networks. Diana, thank you so much for coming on the Principled Podcast. Diana Sands: Thank you, Marsha. It's great to be here. Marsha Ershaghi Hames: Let's kick off. Diana, you had an accomplished career, retiring as an executive officer and senior vice president in the office of internal governance and administration at the Boeing Company. And you have now turned to service on corporate boards. Your career has spanned a variety of leadership roles across multiple industries and disciplines. Maybe for our listeners, we can kick off by hearing more about, just tell us about your background and career and how this has informed your approach to serving as a director. Diana Sands: Sure. And thank you again, Marsha, for having me. As you noted, across 30-plus years, I worked in various industries, including professional services, consumer products, and industrials, mostly in finance roles. I held several finance leadership positions, including corporate controller at Boeing. And my last role, as you alluded to, before I retired, was reporting to the CEO and the audit committee in a chief administration and chief ethics and compliance role. As you also mentioned, I currently serve on both public company and nonprofit boards. Marsha Ershaghi Hames: How has this experience started to really shape or inform your approach to serving as a director? Diana Sands: You know, Marsha, I think the breadth of my experience is mainly what shapes me as a director. I've been part of a lot of different business opportunities and challenges. And with that, I tend to think pretty holistically, whether it's assessing an opportunity starting with a strategy all the way to how it can be practically executed, or dealing with a particular challenge, which often means quickly yet systematically gathering facts, evaluating options, and then taking actions. I do believe that the best way to leverage experiences is not to automatically duplicate what one has done in the past. In fact, I don't really love hearing a director simply stating, "This is what we used to do at XYZ Company." I think the greater value from past experiences is a director's ability, because of those experiences, to quickly absorb an existing situation and think through the possible outcomes. And that's the approach I tend to try to take in the boardroom. Marsha Ershaghi Hames: We're going to dive into some of how you're transferring some of your unique background as a compliance and ethics officer into the boardroom. But first, I want to take a step back. I mean, when I look across 30 years, across all the sectors that you have developed your career in, you were probably or likely one of the few women executives in these fields. I'm just curious, as you look back, were there any mentors or, I'll use the term sponsors, that sort of provided more guidance, influence, coaching through developing your career journey? Diana Sands: Yeah, definitely. And I think you're right. I was often the only female and/or minority in rooms during my career. I do think the good news is that it's changing, albeit maybe slowly, but it's changing across all sectors. But having said that, mentors are definitely important, and I had several great ones. Most of them, by the way, were white males because that's who I was primarily working with. But I remember one very early in my public accounting career, a manager who showed me tough love as he reviewed my work papers. He was really hard on me and my work, but it was formative in the way I think today. In fact, that holistic approach I mentioned earlier is in large part thanks to this person who taught me early on to always think about that bigger picture. And then later in my career, another mentor, one of the CEOs I worked closely with, pushed me to aspire for more than I might have otherwise. He's the one who coached, or maybe coaxed is the better word. He coaxed me to take on some roles that went beyond my comfort zone. But ultimately, those were the roles that enabled me to ascend to the C-suite, which also was critical in getting my current board positions. Those are a couple mentors, I've had several, but I think the common thread across all

What you'll learn in this podcast episode What is top of mind with board directors when they think about corporate culture, ethics, and compliance? How can leaders best assess culture in the companies they oversee? In the season 8 premiere of the Principled Podcast, LRN Director of Advisory Services Emily Miner is joined by Dr. Marsha Ershaghi Hames and Dr. Eric Baldwin at Tapestry Networks to discuss how board members can improve oversight. Listen in as the group shares insights from Tapestry Networks and LRN’s joint report Assessing Corporate Culture: A Practical Guide to Improving Board Oversight, which draws from a working group of nearly 40 directors and executives representing over 60 public companies. Principled Podcast Show Notes [0:29] - Emily welcomes listeners to this episode with Marsha and Eric of Tapestry Networks.  [1:46] - A discussion on the recently published report, “Assessing Corporate Culture: A Practical Guide to Improving Board Oversight.” [6:14] - Why the report offers a practical framework and what needs it seeks to address. [9:59] - The key findings or pillars of the report. [15:22] - How the report helps leaders answer “How?” questions. [20:30] - What is the potential broader impact of the report?   Featured guest: Dr. Eric Baldwin Eric Baldwin is a principal at Tapestry Networks, working with teams in the firm’s corporate governance and financial services practices. Prior to coming to Tapestry, he served for several years as a research associate at Harvard Business School (HBS), where he collaborated with faculty on a variety of research and writing projects covering topics ranging from organizational culture and change management to corporate strategy and healthcare policy. Prior to his time at HBS, Eric taught in the religious studies departments at Franklin & Marshall College and Boston University, while earlier in his career he served in engineering and operations roles at ON Technology Corporation, a software development firm based in greater Boston.  Eric holds a PhD in religious studies from Boston University and a BA in history from the College of William and Mary.   Featured guest: Dr. Marsha Ershaghi Hames Dr. Marsha Ershaghi Hames is a partner with Tapestry Networks and a leader of our corporate governance practice. She advises non-executive directors, C-suite executives, and in-house counsel on issues related to governance, culture transformation, board leadership, and stakeholder engagement. Prior to joining Tapestry, Marsha was a managing director of strategy and development at LRN, Inc. a global governance, risk and compliance firm. She specialized in the alignment of leaders and organizations for effective corporate governance and organizational culture transformation. Her view is that compliance is no longer merely a legal matter but a strategic and reputational priority.  Marsha has been interviewed and cited by the media including CNBC, CNN, Ethisphere, HR Magazine, Compliance Week, The FCPA Report, Entrepreneur.com, Chief Learning Officer, ATD Talent & Development, Corporate Counsel Magazine, the Society of Corporate Compliance and Ethics and more. She hosted the Principled Podcast, profiling the stories of some of the top transformational leaders in business. Marsha serves as an expert fellow on USC’s Neely Center for Ethical Leadership and Decision Making and on the advisory boards of LMH Strategies, Inc. an integrative supply chain advisory firm and Compliance.ai, a regulatory change management firm. Marsha holds an Ed.D. and MA from Pepperdine University. Her research was on the role of ethical leadership as an enabler of organizational culture change. Her BA is from the University of Southern California. She is a certified compliance and ethics professional.   Featured Host: Emily Miner Emily Miner is the Director of Advisory Services at LRN’s Ethics & Compliance Advisory practice. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.     Principled Podcast Transcript Intro: Welcome to the Principled Podcast brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Emily Miner: What is top of mind with board directors when they think about corporate culture, ethics and compliance? How can leaders best assess culture in the companies they oversee? Hi, and welcome to another episode of LRN's Principled Podcast. I'm your host, Emily Miner, director of advisory at LRN. And today I'm joined by Dr. Marsha Ershaghi Hames and Dr. Eric Baldwin partner and principal respectively at Tapestry Networks. We're going to be talking about corporate culture and how board members can improve oversight. Marsha and Eric have just collaborated with us at LRN on a report entitled, "Assessing Corporate Culture: A practical guide to improving board oversight." The report presents insights from a working group of nearly 40 directors and executives representing over 60 public companies, including some of the largest companies in the world: Cigna, Sony, McKesson, Lockheed Martin, CDW, Coca-Cola, Excel Energy and Palo Alto Networks included. Marsha, Eric, thanks for joining me on the Principled Podcast today. Marsha Ershaghi Hames: It's great to be here. Eric Baldwin: Thanks for having us, Emily. Emily Miner: Okay, so let's jump right in. This report, a guide really, assessing corporate culture is the result of working group sessions of the ethics, culture and compliance network. Marsha, let me start with you. What is the ECCN, who are its members, and how did it come to be? Marsha Ershaghi Hames: Sure. Great. We're happy to continue to share the Ethics Culture Compliance Network progress. This network was founded in the summer of 2020. I mean, it was during the thick of a pandemic. Companies were spiraling. It was just a lot of crisis management and companies were starting to take a real reflective step back. They were assessing where do we need to look? How do we need to assess our planning for longer term future? And the conversation emerged initially, Emily, as a forum. It was a safe space to convene. Public company directors and senior executives, namely chief ethics and compliance officers, to really start exploring values, corporate culture and the role of ethical decision making in business. Emily, if I can highlight just a few key aspects that the stakeholders of ECCN started to really prioritize over the last two years, number one, the need for boards and executive teams to align and articulate culture so that management feels supported. Number two, to address the challenge of getting ethics and culture on board agendas and to really promote directors going deeper with management, we're going to get to shortly. Number three, ECCN stakeholders have continued to really want a forum to share peer to peer examples, pragmatic examples of the need for better communication and greater transparency between the CECO, the broader management team and the board. Emily Miner: Thanks, Marsha. Having sat in on some of these sessions, I know that those specific examples that you just alluded to, those were among some of the most powerful conversation prompts. So I think that the members got a lot of value out of that. I certainly know I did. And so this report builds on a report that we, Tapestry Networks and LRN, collaborated on last year, activating culture and ethics from the boardroom, which was a really insightful temperature check on board's attitudes about culture. Eric, can you talk about that project and how it led to this latest one? Eric Baldwin: Sure. With the last year's activating culture report, we had set out to understand the realities facing boards and their oversight of ethics and culture. What were their key concerns, the challenges they face, current practices. So to get at that, we interviewed 40 directors who occupied about 80 seats on public company boards with the aim of getting a really broad view of board oversight of ethics and culture. What we found was a pretty diverse range of practices across boards, in terms of what kinds of information they were receiving, their engagement with their management teams, including how often they heard from their chief ethics and compliance officer, a range of assignments of committee responsibilities and really it's just a variability and how much attention the issues get from boards. We also found a real lack of comfort among directors. So directors recognize the importance of culture and the risks associated with ethical lapses or with unhealthy cultures, but recognize that their ability to oversee culture doesn't have the level of clarity and rigor that you find in other aspects of board oversight, like say financial re

What you'll learn in this podcast episode Is trust the ultimate currency of stakeholder capitalism? If so, how can corporate leaders create a culture of trust inside and outside of their organizations? In the final episode of season 7 on the Principled Podcast, host Jen Uner talks about the role of values in building organizational trust—and frameworks to help you get there—with LRN Director of Advisory Services Emily Miner. You can listen to the other season 7 episodes mentioned in this discussion here: How values inform decisions: Unpacking the role of the CECO Trust is at stake, and other insights from Edelman's 2022 Trust Barometer You can access other materials mentioned in the discussion here: Aspen Ideas Fest panel discussion with Ellen McGirt Corteva case study LRN Benchmark of Ethical Culture   Featured guest: Emily Miner Emily Miner is the Director of Advisory Services at LRN’s Ethics & Compliance Advisory practice. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.   Featured Host: Jen Üner Jen Uner is the Strategic Communications Director for LRN, where she captains programs for both internal and external audiences. She has an insatiable curiosity and an overdeveloped sense of right and wrong which she challenges each day through her study of ethics, compliance, and the value of values-based behavior in corporate governance. Prior to joining LRN, Jen led marketing communications for innovative technology companies operating in Europe and the US, and for media and marketplaces in California. She has won recognition for her work in brand development and experiential design, earned placements in leading news publications, and hosted a closing bell ceremony of the NASDAQ in honor of the California fashion industry as founder of the LA Fashion Awards. Jen holds a B.A. degree from Claremont McKenna College.      Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Jen Uner: Is trust the ultimate currency of stakeholder capitalism. If so, how can corporate leaders create a culture of trust inside and outside of their organizations? Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Jen Uner, strategic communications director at LRN, and today, I'm joined by my colleague, Emily Miner, director of advisory services. We're going to be talking about the role of values in building organizational trust and frameworks to help you get there. Emily, thanks for joining me today on the Principled Podcast, by the way, our final episode of this season seven. Emily Miner: Yeah, thanks for having me, Jen. I'm happy to be here and honored to be rounding out an incredible season on the Principled Podcast. Jen Uner: It has been a great season, and I think we're going to have an opportunity to touch on some of the folks that we've had on the podcast. To get us started though, recently at Aspen Ideas Fest, Fortune senior editor, Ellen McGirt, asked a great question of her panel. She said, "Is trust the ultimate currency of stakeholder capitalism?" It's how we started our conversation today. I of course will say yes, but recently, you spoke with David Bersoff, head of Global Thought Leadership Research at Edelman, and he worked on the Edelman Trust Barometer. You had a chance to speak with him earlier this season, and I'd love for you to recap for us some of the insights that stood out to you. Emily Miner: Yeah. I think based on the 2022 Edelman Trust Barometer, which is a fantastic annual look at levels of trust in key societal institutions, business, government, media, I think that the 2022 Trust Barometer report would say that the answer to your question and to Ellen's question is yes, trust is the ultimate currency of stakeholder capitalism. In fact, what Edelman found in their research is that business is the only institution in our society that is trusted, and that's actually a first in the 20 plus years that they have been running this type of study. Actually, for the second year in a row is business the most trusted institution. That was one of the takeaways from the Edelman Trust Barometer, and that David helped unpack when we spoke earlier this podcast season. Given that, if business is the only trusted institution for the second year running, it really underlines the question, what does this mean for leaders? How can they ensure that business remains trusted? People are looking more and more to business to help solve or address the problems of the world because we don't trust government, because we don't trust media, because we don't trust NGOs. With that mantle of being the only trusted institution, a lot more is falling on business and specifically business leaders and the expectations for them are a lot higher. I think that that really ... That was a current through the Aspen Ideas Institute that you mentioned through the conversation that took place there. Jen Uner: It really does put a lot of pressure on CEOs and leaders then. One of the stats that I thought was so interesting was how I think it was 60% of employees, they're basing their employment decisions now on the values of the companies that they're looking at and the positions that companies take around social issues, and of course they expect the company to have a position on a social issue, which I thinks it's a rather new thing. Would you say? Emily Miner: Yeah. I don't know if it's new in the past few years because I do feel like this has been a trend that I've observed in the research maybe up to the past decade or a little bit less, but it certainly every year seems to get to ... It grows. I think, first, it was a healthy minority of the global workforce or of the workforce in the United States, and now it's tipping to be a majority of the workforce. You see some of this in demographic changes as millennials grow in the size of our workforce and now Gen Zers as they're entering the workforce and the expectations that those two generations have for their employers. But it's certainly not a concept that millennials invented, but it does seem to be growing. Something that's interesting to me now where despite ... We're potentially heading toward a recession in the United States, and despite that, it's still very much an employee market out there. We're still in the midst of a great resignation, which is now really being more called a great reshuffling because it's not that people are dropping out of the workforce so much as they're leaving their jobs to find better jobs. What some research has shown is that it's not so much that I can find another job that pays me better, but it's that people are no longer satisfied with the status quo and they're looking for opportunities where they can feel more values alignment, where there's more culture of inclusion and equity in the workplace, where they feel that their company is doing something that's contributing positively to the world. Those are strong drivers of why people are jumping ship and looking elsewhere. It'll be interesting to see how that shapes the narrative and the importance of values and multi-stakeholder capitalism more generally as we continue to hopefully be coming out of the COVID pandemic and this great reshuffling in spite of some of the more negative trend lines with respect to our economy. Jen Uner: Yeah. I was just going to bring that up. When you have a business environment that's marred by an economic downturn, that puts a lot of pressure. There's then the business financial pressure on decision-making and performance for the company. Then you layer on top of that some of the social and political challenges that are happening and this need to have a position, and can you have a position on everything? Which are the things that you need to prioritize? I think often corporate leaders in ethics and compliance, our field, chief ethics and compliance officers, for example, the people listening here, they find themselves in a role of counselor to the C-suite as the company and as leaders are facing these kinds of tough decisions. One of the things that really struck me at that Aspen Ideas Institute conversation was Allstate's CEO, Tom Wilson, was one of the panelists and he spoke about a societal engagement framework. I know you had a chance to listen to his presentation. Can you tell me about their approach to decision-making and how they engage on hot button issues? Emily Miner: Yeah, absolutely. I am so inspired by this framework, and beyond that, there's so much common sense in it, and Tom Wilson talked about this societal engagement framework as something that Alls

What you'll learn in this podcast episode It’s generally accepted that effective E&C programs are based on values as well as rules. But applying those values to real-life situations can be difficult. This has been particularly true during the pandemic, as organizations make hard decisions in many instances and chief ethics and compliance officers play a key role in guiding those efforts. How can values help CECOs sustain ethical performance—and even excel—in the face of such change and adversity? In this episode of LRN’s Principled Podcast, host Susan Divers talks with Scott Sullivan, Chief Integrity & Compliance Officer at Newmont Corporation, and Joe Henry, who just retired as US Compliance Officer at Braskem. Listen in as they discuss the difficult choices they faced in providing moral leadership in their organizations—how those choices were made, by whom, and what the examples say about the role of the CECO.   Principled Podcast Show Notes [1:58] - Scott’s role as the CECO at Newmont Corporation, the challenges faced and how he applies his values. [4:50] - Ethics and compliance at the heart of Newmont’s decision making during the pandemic. [6:10] - Joe’s role at Braskin and the challenges he faced. [11:20] - The role of Joe’s values in influencing colleagues to change the decisions they made. [13:35] - The lessons learned from these tough experiences in the company. [16:12] - How both company’s ethical cultures emerged after the pandemic.  [19:50] - Other circumstances which strengthened the respective ethics and compliance cultures. [27:25] - The most important areas of focus for an ethics leader in resolving difficult questions. Featured Guest: Joe Henry Joe Henry was the US Compliance Officer for Braskem, a multi-national Chemicals and Plastics company headquartered in Sao Paulo, Brazil.  He led the Ethics, Compliance and Risk Management efforts for Braskem’s US operations including commercial, manufacturing, logistics, management and Innovation and Technology (R&D) functions.  Prior to joining Braskem in January 2017, Joe was a Compliance Director at GSK, a global pharmaceutical company, and worked in various ethics and compliance roles since 2003.  Investigations oversight, Compliance Operations, Methodology development, process assessment and improvement, policy and procedure management and managing government oversight programs were some of the responsibilities he successfully fulfilled while at GSK.  Prior to his GSK Compliance roles, Joe worked at SmithKline Beecham as an Information Technology Project Director and with IBM Sales, Technical Support and Product Development.  Joe earned a B.S. in Chemical Engineering from Carnegie-Mellon University and an MBA from Saint Joseph’s University.  He also earned his certification as a Leading Professional in Ethics and Compliance from the Ethics and Compliance Initiative (ECI).  Joe and his wife reside in Lewes, Delaware and he retiredg at the end of March 2022 to pursue personal interests, travel and enjoy more time with his 3 grown children and two grandchildren.  Joe continues to provide advisory and investigation services on an as-needed basis to Braskem’s US Compliance department.   Featured Guest: Scott E. Sullivan Scott E. Sullivan is the Chief Integrity & Compliance Officer of Newmont Corporation, the world’s leading gold company. Newmont has approximately 15,000 employees and 15,000 contractors and has 12 operating mines and 2 non-operated JVs in 9 countries. Mr. Sullivan oversees, develops, implements and manages Newmont’s integrity and compliance program including ethics, anti-bribery, corporate investigations, and global trade compliance. Previously, Mr. Sullivan was the Chief Ethics & Compliance Officer of a global manufacturer of fluid motion and control products with approximately 17,000 employees operating in 55 countries. Mr. Sullivan has written and contributed numerous articles on compliance programs, anti-bribery/FCPA, export controls, economic sanctions and other ethics and compliance topics to a variety of publications. Mr. Sullivan is also a frequent local, national and international speaker, moderator and conference organizer on compliance, anti-bribery/FCPA, export controls and economic sanctions.   Featured Host: Susan Divers Susan Divers is a senior advisor with LRN Corporation. In that capacity, Ms. Divers brings her 30+ years’ accomplishments and experience in the ethics and compliance area to LRN partners and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance and substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program. Mrs. Divers’ background includes more than thirty years’ experience practicing law in these areas. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative. Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Mrs. Divers’ most recent publication is “Balancing Best Practices and Reality in Compliance,” published by Compliance Week in February 2015. In her spare time, she mentors veteran and university students and enjoys outdoor activities.     Principled Podcast Transcription Intro: Welcome to the Principled Podcast brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: Hello, it's generally accepted nowadays that ethics and compliance programs that are effective are based on values as well as rules, but applying those values to real life situations can be difficult. This was particularly true during the pandemic when organizations had to make hard decisions in many instances in unprecedented circumstances, and ethics and compliance officers frequently played a key role in guiding those efforts. How can values actually help ethics and compliance officers sustain ethical performance and even excel in the face of change and adversity?   Well, hello and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, director of thought leadership and best practices with LRN's advisory group. Today, I'm joined by two thoughtful ethics and compliance professionals, Scott Sullivan, the chief ethics and integrity officer at Newmont Corporation, and Joe Henry, who just retired as the US compliance officer at Braskem. We're going to be talking about the difficult choices they face in providing moral leadership in their organizations, how those choices were made, by whom and what the examples say about the role of the chief ethics and compliance officer. Scott, I'm going to start with you. Can you talk about your role as the CECO at Newmont and some of the hard choices you've faced and how you applied your values? Scott Sullivan: Sure. And thank you, Susan. It's exciting to be part of this podcast and it's a subject I'm very passionate about. So while Joe will be tackling some specific examples, I thought it might be more beneficial to start with a bit on process and approach. So when your values are tested in trying times, this is when the rubber meets the road. So the least common denominator approach, or what is accepted, what is condoned, often becomes your culture. It's not the pronouncements and the platitudes, but rather what you do on the ground or in crunch time. So during COVID, which by the way is not yet over or gone, we faced numerous challenges like everyone else, our values of safety, responsibility and integrity were at the forefront of what we did and said every day. As our strategy rolled out, we had to consider the full spectrum of stakeholders from vulnerable indigenous communities in which we operate to suppliers who were dependent on us to our employees.    In some cases in the early days of COVID, we even went into what's known as care and maintenance mode, which is basically shutting down except for essential services to protect the health and wellbeing of a variety of our stakeholders. We also deployed over 20 million in a COVID fund to assist communities around our minds with COVID type issues and challenges. We were active partners in the COVID struggles

What you'll learn in this podcast episode Good training is not quick to create. It takes time, effort, and years of instructional design experience. And too often, best-in-class training gets derailed by inadequate communications. An effective, attention-grabbing communications strategy is just as important as the quality of the learning itself. How can companies ensure that they’re designing training and communications that produce positive learning experiences and—ultimately—business outcomes? In this episode of LRN’s Principled Podcast Damien DeBarra, leader of Curriculum Design and Communications Strategy at LRN, and Tomaso Manca, learning director at LRN, discuss the importance of intentional curriculum design when developing corporate onboarding. Listen as the two talk about what best practices organizations should consider in their approach.   Principled Podcast Show Notes [1:28] - What is meant by the idea of campaigns, not courses? [3:47] - Best practices for incentivizing learners. [6:11] - The benefits for learners. [7:31] - How does LRN approach this campaign-based strategy? [9:46] - Examples of ways to retain the attention of your audience. [11:54] - Tactics used by LRN to bring the idea of campaigns, not courses to life. [15:00] - Tips to ensure people don’t feel overwhelmed by your campaign. [17:30] - The LRN difference in this approach. [20:40] - Advice for people looking to implement this approach for the first time. Featured Guest:  Tomaso Manca has created exciting learning events for more than 20 years. As a Learning Director at LRN, he works with clients to create engaging learner experiences that support behavioral changes.  Before joining LRN, Tomaso spent more than six years as a Learning Manager at Interactive Services. Prior to that, he worked as Best Practices Global Learning Manager at Thomson Reuters, supporting the learning of their Sales Organization.  Tomaso holds an M.A. in Economics from Yale University.       Featured Host:  Damien DeBarra brings more than 20 years’ experience to the instructional design and strategic workforce planning spaces.  As a Senior Advisory Learning Solutions Manager at LRN, he focuses on creating training solutions that ensure business buy-in and connect hiring practices to day-one learning roll-outs. In the last few years, Damien has helped organizations such as United Airlines, Sun Life Financial, SITEL, Astellas, MFS Investments, and SAP create 90-day action plans for their solutions and develop supporting communication strategies. He has worked with over 200 clients in areas ranging from retail to pharmaceuticals, call centers to nuclear plant manufacturing. Prior to LRN, Damien spent more than nine years as the Learning Solutions Director and Head of Instructional Design at Interactive Services. He has also worked as an instructional designer at NCALT, Electric Paper, and Epic. Damien received his BA from Maynooth University.     Principled Podcast Transcription Intro: Welcome to the Principled Podcast. Brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Damien DeBarra: Good training is not quick to create. It takes time, effort, and years of instructional design experience. Best in class training is too often ruined by inadequate or authoritarian style communications. An effective attention grabbing communication strategy is just as important as the quality of the learning itself. So, how can you ensure that you're designing training and communications that produce positive learning experiences and ultimately positive business outcomes? Hello, and welcome to another episode of LRN's Principled Podcast. I'm Damien DeBarra, the leader of curriculum design and communication strategies at LRN. Tomaso Manca: And I'm Tomaso Manca, learning director at LRN. As co-host for this episode, we are going to be talking about the importance of intentional curriculum design when developing corporate onboarding, and what best practices to consider in your approach. All right, Damien, let's dive in. Something I've been hearing a lot at LRN is the idea of campaigns and not courses. What do we mean by that? Damien DeBarra: So campaigns, not courses, it's taken from the name of a talk we did recently at the Learning Technologies Conference in the UK just a month or two ago. And it's reflective of a conversation, which we have a lot here at LRN, which you hear in production, in our delivery teams and in the advisory team where I work. And that is the... We often semi-jokingly refer to it as, "the tragedy." "The tragedy" is that, we see world class learning materials being delivered to the business with a sort of, "or else" style communication. So if you think about it like, the client comes to us and says, "look, it's really important for us to roll out this training initiative around..." For example, B E and I, we make them a world class e-learning course. We develop a brilliant interactive classroom version of that for those who can't do online. We animate fully bespoke, beautiful videos. There's a whole plethora of support materials ready for the learners to help apply to the job. And the people who've partnered with us are really super psyched and can't wait for the business to get at this. But then the email goes out saying, "Hey, do this course by Friday, or else." It's devastating to your efforts, because as we sometimes like to joke a little bit, people who take online training, particularly online training, they're a little bit like people who ring call centers. And that is that they're already slightly irritated before they get to you. And if you do anything to give them an opportunity to opt out, to give them an opportunity to let that email slide down the inbox and just be ignored, they'll likely grasp it. And it's not because people don't want to learn on the job, it's simply that it's one email and another hundred inside of the day. They've probably got a job to do. They've already got training. They might be behind on... So any kind of blunt order to do a course really doesn't help. So instead, what we try and do is catch people's attentions and then incentivize them, or if you like, seduce them or draw them towards actually exploring those learning assets. Tomaso Manca: Very interesting, Damien. Can you share the best practice for incentivizing learners? Damien DeBarra: Sure. Well, we tend to do it slightly differently for... with each client, with each partner and differently for each communication strategy, depending on what's being taught or what needs to be learned. But there does seem to be an emerging best practice and it is nascent, it's really emerging, but that is the move away from what you might call the one and done training deployment towards a more campaign based approach. Campaigns, they're spread out over slightly longer periods of time. The amount of minutes a learner spends in their chair doing the training should be the same, or if even possible, less than whatever they did the previous year. But the campaign is spread out rather. And it's made up... The idea is use microburst trainings and snappy communications. Really engaging videos, try and keep them under one minute, two minutes, maximum. Job aids with exploratory questions to help you focus, and then whatever the medium, whatever the channel, we try and focus on using simple repeated messaging across a period of time in multiple channels.  And if possible, we try and get that messaging going through the business, not just from an actor, as aware in a voiceover, but rather from real people within the organization. So real people within that business, diverse voices and if possible local leaders. So it brings a degree of authenticity to it, but again, back to that idea of, we need to catch people's attention. So whatever communication it is you're sending out around your training launch, it really needs to get people's attention. It has to stand out from the other 99 emails that you might have received that day. The response we want is, we want people to see a headline in an email and go, "oh, what's that?" And click to open it. And it's... It is about drawing people in and avoiding the language you normally associate around training. The very instructional designer language, the very people and culture departments. So human resources department's language, moving away from all that language around learning and trying to make it sound and feel not like training but more like a marketing campaign for something really cool. That's going to make you better at your job. Tomaso Manca: So we're talking about using language that draws the learner in, within a campaign based strategy. What are the benefits for our learners? Damien DeBarra: Well, there's a number of them, as we said, the first one is to try and take the sting out of being asked to do training when you've already got a multiple... a long series of tasks to do in your day. So as we said, we know people, a lot of people... if we give them an opportunity to leave that email alone, they will. Also... I alluded to this a couple of months ago, that language of instructional design we're all kind of used to hearing, "by the end of this course, you will be able to..." Whilst that has its place, if we can use a different kind of tone and approach, what you might call a more magazine style of writing, it's much more human. It's much more relatable. And it benefits the learner because, basically we want to try and increase and drive engagement.    So it's about trying to make the materials not sound like training, it's something that's going to be where you're being talked at. And the benefit of the learner is, as I say, primarily engagement. Keep them guessing, kind of engaged in thi

What you'll learn in this podcast episode According to LRN’s 2022 E&C Program Effectiveness Report, 56% of the respondents said that integrating major program elements into a mobile app was a high priority for them this year. But what does a “good” mobile solution look like? And how can you ensure it strikes the right balance of meeting compliance needs while creating an engaging—and helpful—user experience? In this episode of LRN’s Principled Podcast, Carolyn Grace, content writer and podcast co-producer, discusses E&C mobile solutions with María Fernanda Castañeda Zavala, the ethics and compliance manager at Hershey. Listen in as they explore how Hershey leveraged a mobile app to enhance the components, capabilities, and overall brand of their E&C program.   Featured Guest:  María Fernanda Castañeda Zavala serves as the Ethics and Compliance Manager for The Hershey Company. She is responsible for driving the ethics and compliance program effectiveness and awareness across the company. She leads the implementation of training, communications & outreach, policy lifecycle management, monitoring, case management, and co-leads Hershey's Ambassador program. Prior to joining Hershey, she was Ethics and Compliance Analytics Program Manager at Nokia, where she led initiatives to collect, analyze and visualize data to test compliance controls, enabling data-driven decisions to drive continuous program improvements. She holds a Master of Business Administration degree from Montclair State University, New Jersey, and an Accounting bachelor's degree from Escuela Bancaria y Comercial, Mexico. She is a Certified Compliance and Ethics Professional-International (CCEP-I) and a Certified Business Analyst.     Featured Host: Carolyn Grace Carolyn Grace is a content writer on LRN's global marketing team and co-producer of the Principled Podcast. She specializes in writing compelling stories about ethics and compliance that resonate across business segments, industries, and personas while hitting critical KPIs for traffic and engagement. Topics she frequently covers include ESG, data privacy and protection, DEI, the role of boards of directors and leadership, corporate training and e-learning, and ethical corporate culture. Prior to joining LRN, Carolyn was a writer and content strategist at Thinkso Creative, a boutique creative agency in New York City. At Thinkso, she wrote internal and external communications for clients in technology, nonprofit, law, logistics, and financial services sectors. Before that, Carolyn conducted trend research and cultural strategy at Horizon Media, specializing in entertainment, travel, media and technology, health and wellness, and food and beverage categories. Carolyn graduated magna cum laude from the University of Pennsylvania with a B.A. in American History and French Studies and a minor in Journalism.     Principled Podcast Transcription Intro: Welcome to the Principled Podcast brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change-makers. Carolyn Grace: If you want your ethics and compliance program to meet your employees where they are, you need to take mobile seriously. And most E&C professionals know that. In fact, 56% of the respondents to LRN's 2022 E&C Program Effectiveness Report said that integrating major program elements into a mobile app was a high priority for them this year. But what does a good mobile solution even look like, and how can you ensure it strikes the right balance of meeting compliance needs while creating an engaging and helpful user experience? Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Carolyn Grace, content writer and co-producer of the podcast at LRN. Today. I'm joined by María Fernanda Castañeda Zavala, the ethics and compliance manager at Hershey. We're going to be talking about how Hershey leveraged a mobile app to enhance the components, capabilities, and overall brand of their E&C program. Fernanda is a real expert in this space with a background focused on compliance analytics and monitoring. Fernanda, thanks for coming on the Principled Podcast. María Fernanda Castañeda Zavala: Thank you for having me, Carolyn. I'm glad to be here talking about our journey and our ethics and compliance program. Carolyn Grace: I've really been looking forward to this conversation with you as I've been hearing nothing but success stories coming out of Hershey's mobile E&C solution. For those who aren't as familiar with your story, can you start by sharing what Hershey's ethics and compliance program was like before the app came along? What were the challenges or opportunities you wanted to address at the time? María Fernanda Castañeda Zavala: Certainly Caroline. Well, at Hershey, we are a purpose driven organization and our ethics and compliance program is designed to promote an organizational culture that encourages ethical behaviors and lives our shared values of togetherness making a difference, excellence, and of course, integrity. Our program overall is guided by a suit of carefully crafted policies and processes developed to keep us competitive, prepared and resilient. Back in 2020 and motivated by the 2020 DOJ compliance guidance, one of our priorities in the program was to understand how our colleagues were interacting with our set of policies, our code of conduct and general information that we were putting together around our program. Our goal was to be able to measure our program effectiveness. So various data points to identifying trends, patterns, KPIs, or potential gaps. At that point, we used to have our policy library on the internet and had the limitation that we weren't able to get any insights on the number of views or searches in the code or our policies. We were looking to streamline the process to providing training, access to our concern line, that's the way we call in Hershey, our helpline, our code of conduct and overall, the policy information. That is when we thought about having all in one place that could allow us to have metrics and provide all resources in a consolidated way. We were conscious that we wanted to do it in a way that allow our colleagues to get our information in easy to access way and ideally, on the go. We know that a good part of our workforce is not in front of a computer the whole time. And we're looking to ensure they have the support needed at their fingertips, an easy way to ask for help when required. That is when we realized a mobile app with the correct capabilities would allow us to achieve this goal. And we did our research and start working toward this objective. Carolyn Grace: That makes a ton of sense. I think, especially hearing you talk about the ease of access and being on the go, we are in a 21st century workforce. There's no surprise there that many people are away from desktops and laptops and using their mobile devices. So your logic behind building this program into a mobile app makes a ton of sense. So let's talk about the mobile solution itself. What did you ultimately build into your E&C app and what was your reasoning behind choosing those particular elements to achieve the objectives that you were just talking about? María Fernanda Castañeda Zavala: Perfect, yes. So as I said, we wanted to monitor our effectiveness. So our goal was to have one stop shop for ethics and compliance needs. That is why we focused on some elements that were core to our program and we wanted to make sure all of them were included in our app. Those elements are our code of conduct, our policy library, our reference guide library, or job aid library. We needed to have a direct access to our concern line and either access to our learning management system to allow our colleagues to complete their trainings on ethics and compliance, or any training overall throughout the app. And we also wanted to have a direct access to our monitoring processes, like for example, disclose a conflict or any of the processes that we have in place in the program. We were able to design an app that is user friendly, easy to navigate and where employees can find the content in their local language. That was also an important inclusion aspect that we wanted to ensure in the app. As an example, the code of conduct is organized by section. So the end user is able to go directly to the area of interest or search on any specific content. Let's say, if I am looking to understand the company's stand on retaliation, I can go to the specific area or search by the term and the app will provide me all the resources available around that topic. Our user interface is set up in English, but the end user can select the language they want to see the content in. So we have that flexibility built in, in the app. For example, if a colleague based in Mexico will like to see all the content in Spanish, they are able to do so, selecting their preferred language and the content in the language is automatically showed. For us, it was important to include languages, to empower all employees to have the and compliance information in their fingertips. The app also helped us to consolidate in one place, all monitoring processes, as I said, that we have in place. Our colleagues don't need to look around in the internet or different portals to find where to disclose a potential conflict, where to declare some hospitality or any of our processes. They can get into the app and find the proper links there. The app is also a way to facilitate access to our LMS. Our colleagues can complete their trainings from their mobile phones or tablets. These greatly benefits employees that are not in front of a computer all the time, as we just highlighted. Overall, one of our main objectives was to measure program effe

What you'll learn in this podcast episode Over the last 20 years, codes of conduct have undergone an evolution. Originally written as textbook-sized rulebooks, codes now seek to be visually engaging, readable, and useful guides to employees to help them do the right thing. And rather than covering all manner of what you can and cannot do, today’s codes aim to illustrate values-based principles of what you should and should not do. But these changes are no small task. How can organizations ensure they are designing and implementing their codes to deliver effective and meaningful change? In this episode of LRN’s Principled Podcast, Senior E&C Advisor Jim Walton talks about code reinvention with Carmen Jandacek, the Director of Ethics and Total Rewards at Arizona Public Service (). Listen in as the two discuss how APS reinvented their code of conduct to better reflect their organization’s culture, values, and employee experiences.   Principled Podcast Show Notes [2:02] - Carmen shares about her career background and getting into the ethics and compliance space. [4:07] - What is Arizona Public Service (APS)? [5:20] - The key drivers which led APS to undertake reinventing their code of conduct. [7:40] - The process of updating APS’s existing code. [10:11] - How was the code rewrite accepted among stakeholders? [12:10] - How did the reworked code turn out in the end? [13:35] - Carmen’s advice for other ethics and compliance teams who are thinking about updating their own codes.   Featured Guest: Carmen Jandacek Carmen has worked for Arizona Public Service (APS) since 1996 and is currently the Director of the Ethics Office, Total Rewards, Health Services, HR Operations & Technology. Carmen is the Founder and President of the APS LGBT Alliance, an employee network group, a board director of the Better Business Bureau serving the Pacific Southwest, board member of one•n•ten a local nonprofit and a member on the Greater Phoenix Chamber of Commerce Diversity & Inclusion committee. Carmen has an undergraduate degree in management, and she earned her MBA from the University of Phoenix in 1999.  Carmen is an avid health enthusiast and believes the key to leadership success is a healthy mind and body.  She has participated in many biking, running and triathlon races and is an Ironman Arizona finisher.   Featured Host: Jim Walton Jim Walton is a member of LRN’s Ethics & Compliance Advisory Services Team – with over 25 years of professional experience in corporate, institutional and government settings, spanning the fields of ethics and compliance; environment, health and safety; and energy management. Since 2002, Jim has been passionately dedicated to corporate ethics and compliance – designing, developing, implementing and enhancing constantly-evolving, comprehensive, best-in-class, global ethics and compliance programs. Jim has extensive experience in writing, producing and communicating codes of conduct and corporate policies; designing, managing and implementing ethics & compliance risk assessments; implementing anti-compliance and bribery initiatives; conducting third party due diligence reviews; and helping managers at all levels become better ethical leaders. Jim is a Certified Compliance and Ethics Professional.   Principled Podcast Transcription Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace changemakers. Jim Walton: Over the last 20 years, codes of conduct have undergone an evolution. Originally written as textbook-sized rule books, codes now seek to be visually engaging, readable, and useful guides to employees to help them do the right thing. Codes have also shifted their organizational priorities. Rather than covering all manner of what you can and cannot do, today's codes aim to illustrate values-based principles of what you should and should not do. But these changes are no small task; How can organizations ensure they are designing and implementing their codes to deliver effective and meaningful change? Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Jim Walton, Senior Ethics and Compliance Advisor at LRN. Today I'm joined by Carmen Jandacek, the Director of Ethics and Total Rewards at Arizona Public Service. We're going to be talking about how APS reinvented their code of conduct to better reflect their organization's culture, values, and employee experiences. Carmen has dedicated more than 26 years of her career to shaping the culture, ethics, and compliance at APS, and has real insight into how the company has evolved as a result of its new code of conduct. Carmen, thanks for joining us on the Principled Podcast. Carmen Jandacek: Thanks. I'm just delighted to be here today. Jim Walton: Wonderful. Just to start out, maybe you could tell us a little bit about yourself and how you came into the ethics and compliance field. I'm always fascinated at the journeys that we've all taken to get here. Carmen Jandacek: Absolutely, and mine was absolutely not the traditional way of coming out of college and then going into an ethics and compliance career field. I came to work for APS in 1996, and I spent the first 15 years of my career there on the human resources team. At that point in time, I was really ready for a change. I spent really primarily my time in the space of total rewards, compensation and benefits, and I wanted to look at some other areas where I could expand my career also. An opening came up in our ethics office, and I immediately fell in love with the work. In ethics, you have such an opportunity to not only reinforce and build ethical culture, but the ability to really be the voice of employees and the ethical coach for leaders. It's a really unique role that I have purview and sight to our entire organization, so I can identify trends or issues in one area of the organization and use that as a preventative opportunity and strategy to counsel and coach the rest of the organization. So from my perspective, ethics and compliance work is rich, it's never dull, and it's highly underrated. I think ethics and compliance organizations are the backstop to good governance at any organization. Jim Walton: That's great. I couldn't agree more, and I think your unique background is really a wonderful add to the ethics and compliance community. It's always fascinating to me to see kind of the multifunctional, and the variety and diversity of backgrounds of ethics and compliance professionals, and it only adds to our effectiveness. So, thanks so much for that. I wondered if you could also just set the stage a little bit by giving us a little bit of background about Arizona Public Service, for those who might not know much about your company. Carmen Jandacek: Sure. At APS, we are a subsidiary of Pinnacle West Capital Corporation. We have roughly 6,000 employees, and we serve 11 of the state's 15 counties. We're headquartered in Phoenix, but we are serving primarily the entire state of Arizona. In fact, more than 1.3 million homes and businesses are served by us, and we've made some very bold commitments. We're committed to providing a hundred percent clean, carbon-free electricity to customers by 2050, and we are well on our journey to doing so. We are 50% clean energy today. We also run Palo Verde Generating Station, the nation's largest clean energy producer that is west of Phoenix, and that's really the foundation of our future of carbon-free energy. Jim Walton: Well, that's all very exciting. I know a big part of the commitments that APS is making were instrumental in wanting to rewrite and redesign your code of conduct, and we like to talk about reinventing a code of conduct. So, what were the key drivers that led you and the company to want to undertake this project? Carmen Jandacek: Absolutely. It's been an interesting journey because I also was involved in rewriting the code that we had prior to this code rewrite. We were coming off of a code that was based on policy and procedure, that was framed in policy and procedure, and we had a couple key moments that really culminated in the work that we decided to do. First, we just went through a CEO change. In the CEO change, the CEO, Jeff Goldner, launched a significant culture change throughout the organization. So we wanted to make sure that all of what we were presenting in our code of ethical conduct embodied what that culture change was. Part of the culture change was all about being customer-centric focus, and I fully believe that in order to really deliver on the customer experience, you have to deliver on the employee experience. So, providing frictionless delivery and service, and providing information in a way that is easy for our employees to utilize. So really what we were doing is, from a company perspective, building from the customer backwards to make sure they had a great experience, and I wanted to do the same thing from the code, making our employees with basically the customer of our product kind of front and center. We also, as I just talked about, embarked on the bold new energy commitment to be a hundred percent clean by 2050, and that is really the backbone of the strong purpose that we have, and that needed to be really woven through all of the different documents and all of the different components of the code of ethical conduct. So all of that came together and culminated in us realizing that our current code was not going to help us bring those things to life, it was not going to allow us to bring and capture all of the change that was happening to us as an organization. So we knew that we couldn't just iterate what we had today, we had to completely reinvent that code to support these key initiatives and align with our cultu