Effective Policy Training: Creating Policy Highlights for Compliance, Summaries of Ethics

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TASTES GREAT,

LESS FILLING

DEVELOPING

“POLICY HIGHLIGHTS”

Eric Bottelier Training Lead, NA Ethics & Business Integrity, Sanofi US Adam Oakley Director , Potomac River Partners

SPEAKER INRODUCTION

DISCLAIMER: The views expressed in this presentation are the personal views of the speakers and do not necessarily represent the views of Sanofi US or Potomac River Partners.

› Start with the “Why”

› Philosophy

› Identify where the risk lies

› Quantitative › Qualitative › Survey

› Training approach

› Start with the “Why” › Risk-weighted modular training › Short & engaging user experience › Tailored to your audience

APPROACH

WHY? HOW? WHAT?

THE STORY: WHY?

LAWS CODES POLICIES SOPs WORK INSTRUCTIONS

THE STORY: WHERE THE RISK LIES

› DOJ “Evaluation of Corporate Compliance Programs”

› February 2017 › Common questions used in making individual determination

› Excerpts: Training & Communications:

› Risk-Based: “Has the company provided tailored training for high-risk and control employees…?” › Form/Content/Effectiveness: “Has the training been offered in the form and language appropriate for the intended audience?” › Availability of Guidance: “What resources have been available to employees to provide guidance relating to compliance policies?”

› Excerpts: Policies & Procedures:

› Design: “What has been the company’s process for designing and implementing new policies and procedures?” › Accessibility: “How has the company communicated the policies and procedures…? How has the company evaluated the usefulness of these policies and procedures?”

› Philosophy

› If behaviors don’t change, the training didn’t work › Principles vs. Policies › Understand the why behind the what

› Training approaches

› CIA training › Risk-weighted training › Commercial-based training

› Goals

› Simplify information exchange › Support a learning environment › Creates an engaging user experience

THE STORY: TRAINING APPROACH

› Challenges with traditional

policies/training

• Excessive information
• Difficult to access/retain
• Multiple employees asking identical questions

› Simplify policy information

with policy highlights

MAKING POLICIES STICK

› Identify the most

important policy topics

• Pinpoint areas of potential non-compliance

› Architect information into

relevant focus areas

• Example: Commercial vs. Medical Interactions

› Use clear and concise

language

› Address recurring

questions through Q&A’s

DEVELOPMENT: CRAFTING POLICY HIGHLIGHTS

DEVELOPMENT: CRAFTING POLICY HIGHLIGHTS

DEVELOPMENT: CRAFTING POLICY HIGHLIGHTS

DEVELOPMENT: CRAFTING POLICY HIGHLIGHTS

LAUNCH: VIDEO

MANAGEMENT

PLANNING & PREPARATION

› Facilitate efficient

downstream updates

› Frequent communication

between departments

› Update training regularly

IMPLEMENTATION & DISTRIBUTION

› Store new documents on

Intranet / Sharebox

› Communicate changes to

appropriate employees

› Distribute via email, website,

app, or print material

› Positive feedback

from employees

› Limited redundant calls

to company hotline

› Anecdotes:

› Another division wanted to use the highlights as their policies › Support during monitoring interactions

MEASURING SUCCESS