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CEB Compliance & Ethics Leadership Council
The Next Generation of Compliance and Ethics Program Effectiveness
From Bolt-On to Built-In
Jennifer Kugler
SCCE Conference
October 2017
2
A Framework for Member Conversations
The mission of Gartner’s CEB Leadership Councils is to help executives and their teams harness their growth potential by taking insights from the best companies to save
time and make better decisions. When we bring leaders together, it is crucial that our discussions neither restrict competition nor improperly share inside information.
All other conversations are welcomed and encouraged.
Confidentiality and Intellectual Property
These materials have been prepared by Gartner, Inc. and/or its affiliates (“Gartner”) for the exclusive and individual use of our CEB Leadership Council member
companies. These materials contain valuable confidential and proprietary information belonging to Gartner, and they may not be shared with any third party (including
independent contractors and consultants) without the prior approval of Gartner. Gartner retains any and all intellectual property rights in these materials and requires
retention of the copyright mark on all pages reproduced.
Legal Caveat
Gartner, Inc. and/or its affiliates (“Gartner”) is not able to guarantee the accuracy of the information or analysis contained in these materials. Furthermore, Gartner is
not engaged in rendering legal, accounting, or any other professional services. Gartner specifically disclaims liability for any damages, claims, or losses that may arise
from a) any errors or omissions in these materials, whether caused by Gartner or its sources, or b) reliance upon any recommendation made by Gartner.
2© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
3© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
WE’VE COME A LONG WAY
Representative Examples of the Progress Compliance Programs Have Made
72%
Programs that train
managers on how to respond to employee reports of misconduct.
70%
Programs that provide
annual ethical decision-
making training to at least half of employees.
61%
Programs that track
changes in employee perceptions of the organization’s culture.
Source: 2014 CEB State of the Compliance & Ethics Function Survey.
Manage Compliance and Ethics RisksImprove Employee
Decision Making
Lead the
Function
Define
Program
Mandate
Mitigate and
Monitor
Risks
Establish
Policies and
Procedures
Oversee
Allegations of
Misconduct
Provide
Training and
Communica-
tions
Reinforce
Behavioral
Expectations
Manage the
Function
3
4© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
Identify the Need for a Third Party
Conduct an RFP
Select a Third Party
Onboard the Third Party
Monitor Third-Party Performance
STILL LARGELY A BOLT-ON
Typical Process for Receiving Compliance Approval on a New Third Party
Business Workflow: Select and
Onboard a New Third Party
Compliance Workflow: Conduct
Third-Party Due Diligence
Review and
Approve Third Party
Creates actual burden for
employees through extra steps and
handoffs.
Creates perceived burden because
employees must step outside of
their workflows.
Source: CEB 2015 Third-Party Risk Diagnostic.
a Median number of business days required for Compliance to complete due diligence.
Median Time Elapsed:
17 Business Daysa
5© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
A RISING CHORUS TO EVOLVE OUR PROGRAMS
Changes in Stakeholders’ Expectations of Compliance and Ethics Programs
Compliance and Ethics
Employees
Expect any additional asks of them to be low-
effort
Boards
Expect more clarity on risk exposure and mitigation plans
Regulators
Expect Compliance to be integrated into operations
Senior Business Leaders
Expect results with minimal business drag
Source: CEB analysis.
4
6© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
BOARDS PUSHING FOR A CONSISTENT VIEW OF RISK
Factors Driving Changes in Board Expectations of Compliance and Ethics
External Pressure on BoardsThe Yates Memo and high-profile corruption and privacy failures have pushed the Board to be better informed and more active in risk management.
Corporate Investments in Assurance
Boards expect the heavy corporate investment in assurance to facilitate a clear and accurate sense of risk exposure.
Conflicting Risk Information from Assurance Functions
Assurance functions often provide the Board with inconsistent or conflicting opinions on risk exposure.
Source: CEB analysis.
7© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
0%
35%
70%
0%
35%
70%70%
59% 59%
42%
Source: CEB 2016 RiskClarity.
a Compliance and ethics requirements (training, approvals, documentation, etc.) slow my ability to achieve my business objectives.
Impact of Perceptions of Burden on Compliance OutcomesChange in Outcomes Between Employees Who Perceive Compliance as Low Versus High Burdena
60% Report More Work
+ +Asks from
11 Assurance Functions
More Training, Processes, and Requirements
Employees Who Retain Key Training Messages
Employees Who Report Observed Misconduct
Perceive Low Burden Perceive High Burden
n = 24,697. n = 3,088.
Source: CEB 2015 Careers Panel Survey.
UNDER PRESSURE, EMPLOYEES DEMAND EFFICIENCY
Assurance-Related Pressures Adding to Employees’ Base Workload
5
8© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
WHAT IT MEANS TO BE BUILT-IN
What Compliance Must Do to Build Compliance Activities into Business Operations
Source: CEB analysis.
Assess
For burden and
integration
Built-In
Compliance
CoordinateWith related
assurance
activities
DesignTo be part of
business
workflows
Coordinated With:
Similar assurance activities that could cause overlap and unnecessary burden on employees
Designed To:
Be natural parts of business processes
Avoid extra steps and handoffs
Achieve business goals
Assessed For:
Ease of compliance
Degree of activity integration into business workflows
9© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
FROM BOLT-ON TO BUILT-IN
Design Compliance
to Be Part of Business
Workflows
Coordinate Compliance
and Related Assurance
Activities
Assess How Well
Compliance is Built into
the Business
Business-Focused
Control Design
Low-Lift Assurance
Coordination PlansPost-Project Impact
Assessment
1bserve Co.
Function-First
Compliance Training
Assessment of
Embedded Ethics
and Compliance
1 Pseudonym.
6
10© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
FROM BOLT-ON TO BUILT-IN
What Compliance Must Do to Build Compliance Activities into Business Operations
Source: CEB analysis.
Assess
For burden and
integration
CoordinateWith related
assurance
activities
DesignTo be part of
business
workflows
Designed To:
Be natural parts of business processes
Avoid extra steps and handoffs
Achieve business goals
Built-In
Compliance
11© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
MANY OPPORTUNITIES FOR BUILDING-IN
Select Examples
Compliance
Process or Control Bolt-On Built-In
Conflicts of
Interest Disclosure
Annual conflicts of interest
certification campaign
Conflicts of interest disclosures sent
with annual reminders about updates
to benefits and other information
Gifts and
Entertainment
Tracking
Gifts and entertainment tracking in
Compliance’s gift and
entertainment registry
Gifts and entertainment registry linked
to the expense system, enabling
automated data exports
Third-Party Due
Diligence
Compliance questionnaire sent to the
business following selection of a third
party
Compliance risk criteria embedded in
the RFP evaluation process
Manager Training
Compliance training courses
deployed to managers on an
annual basis
HR system links to Compliance’s
LMS to trigger training for newly
promoted managers
Third-Party
Monitoring
Compliance manually gathers
information from business partners
Compliance criteria are built into third-
party performance scorecards
New Product
Development
Compliance reviews and assesses new
products following the development
process
Compliance criteria are embedded in
the new product development process
Source: CEB analysis.
7
12© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
A SIMPLE WAY TO SEGMENT OPPORTUNITIES
Compliance Processes and Controls Integration AssessmentIllustrative
Potential for
Increased Risk
Reduction
High
Low
Gifts and Entertainment Tracking
Third-Party Due Diligence
Conflicts of Interest
Disclosures
Compliance
Investigations
Low High
Source: CEB analysis.
Cost of Building Into Business Operations
Manager-Delivered Communications
Compliance Policy
Management
FOCUS HERE
NOT WORTH BUILDING IN
13© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
FUNCTION-FIRST COMPLIANCE TRAINING
Overview
Dell’s ethics and compliance program embeds compliance training into the broader sales curriculum, which enables
improved employee retention of material and increased performance against sales goals.
Solution Highlights
Business-Oriented Design Principles
A set of functionally-oriented design principles ensures that the training is viewed by functional employees
as something that will help them meet their objectives, and speaks to their natural language, workflow, and objectives.
Targeted Content Sourcing
Collaboration with functional experts allows Compliance to understand the sales (functional) workflow,
enabling function-first design.
Solution-Focused Content Delivery
Structured delivery of content drives two-way dialogue intended to raise solutions that help attendees
better perform their functional tasks while remaining in compliance with company policies.
Company Snapshot
Dell Inc.
Industry: Technology Dell is a privately-owned company headquartered in America that specializes in computer hardware, computer software, IT services, and IT consulting. Dell is one of the largest technology companies in the world, serving customers globally.
2015 Sales: $59 Billion
Employees: 108,000
8
14© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
TRAINING MUST SPEAK TO THE FUNCTION
Design Elements of Dell’s Leading From the Front Training
Where Design Elements Count■ Titling and Labeling ■ Branding of Content ■ Facilitator Scripting ■ Pre- and Post-Training Messaging
Establishing Relevance
Use Business Language
Frame content using the vocabulary that functional
employees use daily to ensure the delivery is seen as
both impactful and credible.
Focus on Functional Workflow
Structure training around the core activities of and
tools used by functional employees.
Connect to Relevant Outcomes
Link concepts and actions to the outcomes that
employees care about.
Source: Dell; CEB analysis.
15© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
HELP THEM HELP YOU
Targeted Questions to Guide Functional Partners on How They Can Best Inform Training Design Illustrative
Source: Dell, Inc.; CEB analysis.
Gather Knowledge About Employees’ Jobs
How do sales people spend most of their time? Which activities are they focused on?
What are the tools employees use in their line of work?
What activities do employees struggle with?
What types of things do they view as distractions?
Understand the Vocabulary of Employees
What words should I never use with a salesperson?
What words get sales people excited?
Uncover the Outcomes Functional Employees Care About
What do employees personally want to achieve in their current roles?
What are sales employees held accountable for?
Understand Which Behaviors You Need to Reinforce
Where might employees struggle to be compliant?
How do the best salespeople do their jobs without being noncompliant?
9
16© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
Implementation Guidance for Structuring Actionable Conversations
Two-Way Dialogue Open-Ended Questions Real Examples
Source: Dell, Inc.; CEB analysis.
Source: Dell, Inc.; CEB analysis.
“I have set up peer networking events so prospects can talk to peers
who are satisfied with our product.”
“I’ve seen our Gifts and Entertainment policy, but nice meals is how
everyone wins business.”
Training
Facilitator
“Does anyone have an idea about how to impress prospects without
having to take them out to nice meals?”
Training
Facilitator
“Great idea. You can also simply consider splitting the meal as an
alternative.”
Employee
Employee
STRUCTURED DIALOGUE THAT DRIVES TO SOLUTIONS
How Dell Structures the Discussion to Drive to Actionable Solutions
17© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
93%
RELEVANCE FOSTERS IMPACT
Quantitative Feedback from Sales EmployeesNet Promoter Scorea (NPS), Leading From the Front
Dell’s Leading From the Front training received a high Net Promoter Score which aligns with many of the current modules in the sales training curriculum.
Source: Dell, Inc.; CEB analysis.
a A Net Promoter Score is a measure of how likely training participants would be
to recommend the training to others.
Qualitative Feedback from Sales Employees
“Legal director being together (with salesfacilitator) was terrific. He was able tobring cases which result in a richer class.”
Sales Employee
“Leading From the Front gave me trust in our ethical model facing the customer. I’m more confident on our go to market strategy and how Dell is differentiated in the market.”
Sales Employee
10
18© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
FROM BOLT-ON TO BUILT-IN
What Compliance Must Do to Build Compliance Activities into Business Operations
Source: CEB analysis.
Assess
For burden and
integration
DesignTo be part of
business
workflows
Coordinated With:
Similar assurance activities that could cause overlap and unnecessary burden on employees
CoordinateWith related
assurance
activities
Built-In
Compliance
19© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
LOW-LIFT ASSURANCE COORDINATION PLANS
Overview
National Grid’s compliance program shares planned business interactions with key assurance partners to foster operational
collaboration. Better collaboration reduces burden on the business, improves business leaders’ understanding of risk, and
ensures functional partners are allocating resources efficiently.
Solution Highlights
Short-List of Shared Business Interactions
Share planned business interaction with assurance partners to establish transparency and foster operational
collaboration.
Company Snapshot
National Grid
Industry: Utilities National Grid is an international electricity and gas company based in the United Kingdom and northeastern United States. They play a vital role in connecting millions of people safely, reliably, and efficiently to the energy they use.
Revenue: GB £15.2 Billion
Employees: 23,000
11
20© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
SHORT LIST OF INTERACTIONS WORTH SHARING
Business Interactions to Share with Assurance Partners
Share■ Outreach to Liaisons■ Reports to the Board, Senior Leaders, Audit Committee, etc.■ Meetings with Business Stakeholders on Cross-Functional Topics or Risks■ Planned Changes to Process that Impact Other Assurance Functions
Avoid Sharing■ Function-specific interactions (e.g., privacy impact assessment for Data Privacy)■ Last minute interactions or ad hoc meetings with no formal purpose or agenda
Source: National Grid PLC; CEB analysis.
21© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
April
Monday Tuesday Wednesday Thursday Friday
Weekly Assurance
Function
Conference Call
BU A:
John Smith
Purpose: Reaching
out to risk
champion about Q2
G&E Training
HR
Purpose: Reaching
out about the Risk
module in new hire
training
Risk Committee
Purpose: Update on
data privacy controls
in Q1
Weekly Assurance
Function
Conference Call
HR
Purpose:
Reaching out
about Compliance
module in new hire
training
HR
Purpose: Reaching
out about the Data
Privacy module in
new hire training
BU A:
John Smith
Purpose: Reaching
out to compliance
liaison about G&E
Communication
Planning
Risk Committee
Purpose: Update on
trends in cyber
security and data
privacy in Q1
A CONDUIT FOR COLLABORATION
National Grid’s Shared Assurance Planning CalendarIllustrative
Other Channels for Scaling Information Sharing with Assurance Partners
Source: National Grid PLC; CEB analysis.
Source: National Grid PLC; CEB analysis.
Periodic Assurance Conference Call
Periodic Assurance E-Mail Updates
Compliance Committee Meeting
Periodic WebEx Meetings
Compliance Risk Management Data Privacy
12
22© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
OPPORTUNITIES TO STREAMLINE
Case-In-Point: Coordinated New Hire Onboarding Training
Previous Uncoordinated Approach to Teaching New Hires
About Assurance
Coordinated Approach to Teaching New Hires About
Assurance
New hires receive redundant messaging, leaving them feeling
like the trainings were unnecessary
and unduly burdensome.
New hires receive concise, consistent messaging about
risk and the assurance functions.
Source: National Grid PLC; CEB analysis.
23© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
OPPORTUNITIES TO COORDINATE
Case-In-Point: Coordinated Board Reporting
ERM Board Report
Export/Trade Compliance is a top three risk.
Compliance Board Report
Export/Trade Compliance risk is immaterial.
Do our stories match?
No, Compliance and ERM are reporting different top three risks
Why are our stories different?
“Filing deadlines were missed by Compliance,
the business unit, and Finance, so we may not be
approved for the license we need to move across
borders.”
“A compliance filing deadline was missed, but that does
not constitute a material compliance risk.”
Does this information change our view on the risk this poses?
“Yes, we need to elevate this risk in our report.”
Source: National Grid PLC; CEB analysis.
In cases where this answer is no, we should be able to explain to stakeholders why our stories differ.
13
24© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
Source: CEB analysis.
Assess
For burden and
integration
CoordinateWith related
assurance
activities
DesignTo be part of
business
workflows
Assessed For:
Ease of compliance
Degree of activity integration into business workflows
FROM BOLT-ON TO BUILT-IN
What Compliance Must Do to Build Compliance Activities into Business Operations
Built-In
Compliance
25© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
SEEMS TOO HARD FOR WHAT WE WOULD LEARN
Common Assumptions About Measuring Built-In Compliance
“What will I learn that I don’t already know?”
“These things will be really difficult to
measure.”
Source: CEB analysis.
14
26© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
TOO LITTLE, TOO LATE
Typical Approach to Soliciting Feedback From Business Partners Illustrative
Source: CEB analysis.
January February March April December
Compliance
conducts a risk
assessment.
Compliance
conducts an
investigation.
Compliance
conducts due
diligence on a
third party.
Compliance
Annual Survey
What did you think
about working with
Compliance?
Survey Response
“It’s hard to work with
Compliance. They just
slow us down.”
Too Little, Too Late
Compliance’s ask for feedback is often too
disconnected from the activities respondents
can comment on, so rather than sharing their
specific experiences they often resort to
general feedback which is not as helpful for
Compliance.
27© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
POST-PROJECT IMPACT ASSESSMENT
Overview
After substantive interactions, Etihad assesses business partners’ perceptions of the value Compliance added and the burden
the program created to identify opportunities for improvement.
Solution Highlights
Impact-Oriented Questions
Questions on the impact Compliance created through the engagement—both the value added and the disruption caused—to
better gauge business perceptions and assess Compliance’s performance.
Interaction-Triggered Follow-Up
Timely requests for feedback from specific business partners immediately following a substantive interaction
(e.g., risk assessment, investigation) to receive more actionable feedback on the business’s experience with Compliance.
Process Change Review Criteria
Factors, including feedback volume and patterns, are used to determine when a deeper dive review is necessary to determine
potential process changes.
Company Snapshot
Etihad Airways
Industry: Airlines/ Aviation
As a commercial airline based in Abu Dhabi, Etihad Airways serves more than 85 destinations in 55 countries in Europe, Asia, and the Middle East, and is consistently rated as best airline. Destinations include London, Moscow, Mumbai, Abu Dhabi, Kuwait, and Islamabad. The airline also offers North American services in New York and Toronto.
2014 Sales: US$7.6 Billion
Employees: 25,867
15
28© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
Compliance Engagement Delivery Strongly
Agree
Agree Neither
Agree or
Disagree
Disagree Strongly
Disagree
Comments
Service Quality: The results of the
assignment were delivered within the time
frame set at the start of the engagement.X
Value Added: The assignment added
value to your business area.X
Burden Created: The assignment was
delivered with minimum disruption to
your business. X
Source: Etihad Airways; CEB analysis.
ASK ABOUT TOTAL IMPACT
Sample Questions in Etihad’s Post-Project Survey
Ask About Compliance Impact
Questions about the value Compliance added and the burden it
created provide a clearer picture of the program’s impact than
questions about business partner satisfaction alone.
29© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
Compliance Engagement TeamStrongly
Agree Agree
Neither
Agree or
Disagree Disagree
Strongly
Disagree Comments
The Compliance team member(s)
demonstrated personal integrity and
acted positively throughout the
engagement.
X
The Compliance team member(s)
demonstrated good technical
knowledge of the Compliance area
during all aspects of the engagement.
X
The Compliance team member(s)
were knowledgeable about your
business area.X
Total Score: 60% Rating:
Satisfactory
Source: Etihad Airways; CEB analysis.
ASK ABOUT TOTAL IMPACT
Sample Questions in Etihad’s Post-Project Survey
16
30© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
WHO AND WHEN YOU ASK MATTERS
Etihad’s Approach to Soliciting Feedback from Business PartnersIllustrative
Risk
Assessment
Feedback
Requested InvestigationFeedback
RequestedThird-Party
Approval
Feedback
Requested
Compliance Survey Response
“The action items coming out of the
risk assessment had big budget
implications.”
Compliance
Survey Response
“Going through the investigations
process helped us learn a lot about
where we can improve.”
Compliance Survey
Response
“The approval took almost
two weeks—too long for us
to wait.”
One Week
Tied to Specific Interactions
Asking for feedback from business
partners involved in substantive
projects allows Compliance to
receive more detailed feedback.
Quick Follow Up
Requesting feedback soon after a
project ensures that business
partners will be able to recall
helpful details.
One Week One Week
Source: Etihad Airways; CEB analysis.
31© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
Source: Etihad Airways; CEB analysis.
MORE INPUTS, BETTER UNDERSTANDING
Shift in Etihad’s Understanding of Program ImpactIllustrative
What Employees Perceive■ Employee opinions on how much value Compliance adds■ Employee feedback on how much disruption Compliance causes
What the Program Does■ Number of compliance risks identified and mitigated■ Number of investigations conducted
Result: Compliance has somesense of the risk the programmanaged for the organization(e.g., what they covered).
Result: Compliance sees indicators of whether employees will comply with processes (e.g., how well those risks are likely managed).
17
32© 2017 Gartner, Inc. and/or its affiliates. All rights reserved. CELC174430
How Companies Use CEB RiskClarity
Perform an Employee-
Wide Assessment of
Integrity and Misconduct
Identify Key Focus Areas to
Reduce Misconduct
Uncover the Root
Causes of Misconduct
Contact Us to Learn More
Phone: +1-866-913-8103
E-Mail: [email protected]
Web: cebglobal.com/exbd/compliance-legal/risk-clarity/index.page
■ Detailed analysis of
employee observations ■ Peer benchmarking
results■ Understanding of
employee perceptions
■ In-depth walk-through■ Customized action plan ■ Access to compliance
and ethics resources
■ Full-day workshop■ Metrics and key risk
indicators
CEB RISKCLARITY: A CORPORATE INTEGRITY SERVICETM
Product Features