CREATING AND MAINTAINING AN ETHICAL CULTURE...Ethical Culture Training as a supplement • Training should only be a supplement to the Code of Business Conduct and Ethics and/or online

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CREATING AND MAINTAINING AN ETHICAL CULTURE:How to Get Your Employees to Act Ethically Even When No One Is Looking

BY Jennifer Drost, Chief Ethics and Compliance Officer & Senior Counsel, Travelers Canada

And Tim Glasby, Compliance Director (solicitor) and Money Laundering Reporting Officer, Travelers Europe

Important note

The information provided in this presentation is intended for use as a guideline and is not intended as, nor does it constitute, legal

or professional advice. Travelers does not warrant that adherence to, or compliance with, any recommendations, best practices,

checklists, or guidelines will result in a particular outcome.

The content of this document is only for the informational use of the reader. Information contained herein is not intended as, and

does not constitute, legal or professional advice, nor is it an endorsement of any source cited or information provided. In no event

will The Travelers Companies, Inc. or any of their subsidiaries or affiliates be liable in contract or in tort to anyone who has access

to this document for the accuracy or completeness of the information relied upon in the preparation of this document or for the

completeness of any recommendations from cited sources. Readers should consult source articles for more detail.

This document contains proprietary and confidential information of The Travelers Companies, Inc. and/or its subsidiaries and

affiliates. Do not distribute this document or any part of it to any other person.

Travelers and the Travelers Umbrella logo are registered trademarks of The Travelers Indemnity Company in the U.S. and

other countries.

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How to Efficiently Train and Engage an Entire Organization

ALL RIGHTS RESERVED THE TRAVELERS COMPANIES, INC. 2017 ©

How to Efficiently Train and Engage an Entire Organization

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How to Organize Training:

• Group Size?

• Departments?

• Management/Seniority level?

• Office locations?

Methodology:

• Lecture?

• Q&A?

• Hypotheticals?

• Group work?

• Online or live?

Who Should Train? Customization

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Ethical Culture Training as a supplement

• Training should only be a supplement to the Code of Business Conduct and Ethics and/or online Code training

• The Code training gives the baseline knowledge and understanding, the supplemental training adds colourand practical guidance

• Although rules are set out in the Code, want to give it meaning and make it feel real

• Want to help employees work through possible ethical issues that may relate to them

• Helps to set the culture you are trying to advance in the organization

• The more communication, the better

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Implementing training across the organization

LIVE SESSIONS

Live sessions are great because:

• Open and honest discussions

• Group work brings various thought processes and discussions

• Dedicated attention and no multi-tasking

• Live examples for group discussion

• Interactive “games” or role play

Downside to live sessions are:

• Number of sessions

• How to ensure all smaller offices / satellite / regional offices also have live training

• Getting the group to engage / share

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Who trains?

• When training below the management level, possibly someone senior in the department / business area rather than the Chief Compliance Officer

• Who will get the best out of the group?

Training group sizes can be limited to encourage discussion and more one on one interaction

Organizing sessions by management or seniority level / different levels:

• allows for discussion from a leadership perspective vs. all employees

• employees can speak freely without their manager present

Organizing sessions by function / business area in the company:

• Hypotheticals/ information relates to the specific function/ business area which helps it resonate better with the employees

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What should you include?

• Do you break it up into shorter sessions which are more engaging and stay on one specific topic or do you build a more comprehensive, diverse session?

• Do you have a ‘higher’ risk area which you want to target?

When do you do it?

• Is it periodic?

• Shortly after Code training?

• In between certification?

• Peaks or consistently throughout the year?

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What ongoing training tools can you provide which will enable compliance and generate a strong culture?

• Red Flag Checklists?

• Sample Scenarios?

Simplify or be Comprehensive?

• Who do you want to be the ‘experts’ and make decisions and who needs to know the minimum standards?

• Can you put in escalation points?

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How to Deliver the Message Outside of Training on a Consistent Basis

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How to Deliver the Message Outside of Training on a Consistent Basis

Tools:

• Intranet

• Newsletters

How Often?

To whom? Should messages be customized to different audiences?

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• Policies

• Videos

• Emails

• Posters

• Decision Tree

• Recurring Training


Delivering the Message

Code of Conduct

Annual Policy Certification

Code of Conduct Training

Compliance Awareness / Communication

Ethical Culture Training

Feedback

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Code of Conduct Awareness Video

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Ethics Helpline Anonymity Video

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Ethical Decision Tree example

Although values and expectations may be described in company policies and your company’s Code of Conduct, this decision tree canhelp you in handling difficult situations. If you can’t comfortably answer “yes” to each of these questions, you should stop and seek

advice from your manager. If you have an Ethics or Compliance officer or an ethics helpline, you can utilize that as well.

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1. Is it Legal?2. Does it comply with

company policy?3. Does it support the company’s

culture and values?

6. Could I defend my actions if they appeared in a newspaper

or in a social media post?

5. Would I feel comfortable explaining my actions to my colleagues,

manager and family?

4. Have I considered the impact to our employees, customers?

7. Does it benefit the company as a whole, not just certain individuals?

8. If I am unclear about something, have I asked the

right person for advice?


You’ve Been Caught Doing The Right Thing! (Intranet Article)

To gift card or not to gift card?

Earlier this year, Mr. X, Underwriting Manager, Personal Insurance was faced with a situation he was unsure about. One of our existing inspection vendors visited the Oakville office to provide some training for our underwriters and as part of that, he gave each participant a $10 coffee card. Often times, when you can and when you can’t accept a gift is confusing. To be sure, Mr. X reached out to us to ask if this type of gift could be accepted.

To gift card or not to gift card?

Under our Code of Business Conduct and Ethics, employees are not allowed to accept cash equivalent gifts, which includes gift cards of any amount. In this situation, Mr. X was advised to thank the vendor and return the gift cards, as our Code of Conduct does not allow for this type of gift.

Thanks Mr. X – you’ve been caught doing the right thing!

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It’s Easy to Speak Up! (Intranet Article)

Silence is not an option. Anonymity is.

A key part of being a “do the right thing” kind of place is having employees who know that we honor in

practice what the Travelers Code of Business Conduct and Ethics says in writing about our core values of Honesty, Integrity and Accountability. The Travelers Ethics Helpline is a resource for employees to raise or report issues at work in good faith.

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It’s Easy to Speak Up!

Ten Things You Might Not Know About the Travelers Ethics Helpline

1. No Retaliation – Company policy expressly prohibits retaliation against any employee acting in good faith who makes a report, raises a concern or provides information in response to an investigation.

2. It’s 24/7 – Someone is available to answer the Helpline at all times.

3. It’s online – Submissions can also be made at any time on any internet-enabled device by going to travelers.ethicspoint.com.

4. It’s anonymous – Any report can be made without the reporter revealing his or her identity.

5. It’s completely independent – The Helpline is operated by an independent, third-party vendor. The individuals answering the phone are not our employees.

6. The follow-up can be anonymous – If you report anonymously, you can anonymously follow up on your report with a unique case number. At no point are you required to reveal your identity.

7. It’s really, really anonymous – Because an independent third party runs the Helpline, Travelers cannot see IP addresses or any information about the location or computer of anyone making a report online or calling in to the Helpline.

8. All cases are reviewed internally – Someone in our Ethics and Compliance Office reviews the substance of every single report made through the Helpline phone number or online system.

9. Cases are forwarded to subject matter experts – Reports made to the Ethics Helpline may be referred to different groups within the company for investigation and follow-up.

10. Reporting ethics concerns makes a difference – Reports made in good faith about issues or concerns have a positive impact on policies, procedures and practices at the company.

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Compliance News!

European Initiative for Travelers European entities

• Contains regulatory news and helps circulate messaging throughout divisions

• Also contains standing items for:

– Complaints Corner

– Fraud Focus

– Ethics Helpline

• All have examples of activity from the market place which enable us to show staff good and bad behavior in the market which has had an impact on our peers

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How to Elicit Feedback and Put Ideas Into Place

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How to Elicit Feedback and Put Ideas Into Place

Method for obtaining feedback:

• surveys after training

• Q&A during training

Getting buy in from senior management

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Feedback on training sessions - through surveys

• Soliciting feedback from staff has been critical to our success

• We asked for feedback at our first session (via survey), then implemented some areas for improvement, and then asked for feedback again at random sessions over the next several months

• Here’s a sample of our survey questions:

– Did you feel you could be honest and forthright with your views and that the scenarios discussed were realistic and resulting discussions will be useful when faced with an ethical dilemma in the future?

– How strongly do you agree that each of the Travelers Canada organization, Senior Leadership Team, and your manager, conducts themselves in a manner consistent with the principles discussed in the training sessions

– What was the most valuable part for you about the training?

• Live sessions and group work topped the chart

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Informal Feedback

The way we as Compliance Officers act has a direct impact on the way which our staff interact with us

Many organisations have a Charter or Terms of Reference for their Compliance or Ethics group

It’s one thing having it on paper, it’s another following through on it

• Be transparent

• Invite challenge

• Stop the “gotcha mentality”

• Be empathic; and

• Help them understand the rules

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CREATING AND MAINTAINING AN ETHICAL CULTURE...Ethical Culture Training as a supplement • Training should only be a supplement to the Code of Business Conduct and Ethics and/or online