The short answer is yes, you must train your governing authority, which may be your Board of Directors, on your compliance and ethics program. The U.S. Sentencing Guidelines require that you do so because the Board is required to oversee your program. How does this look in practical terms? Eric discusses what he calls the three pillars of Board of Directors’ training:
- Compliance Risk Topic Specific Training. These topics may include conflicts of interest, anti-corruption, data protection, data privacy, insider training and other specific risk topic training.
- Periodic Review/Discussion of Board of Directors’ Responsibilities. This should address what the Sentencing Guidelines expect of the Board of Directors or other governing authority, including their responsibility for the oversight of the compliance and ethics program.
- Annual Code of Conduct Training/All Hands Training. This is the broader training that goes out to the vast group of employees and other stakeholders that receive training in your organization. Code of Conduct training kills two birds with one stone because it addresses the Board’s oversight role of the compliance and ethics program and it provides actual training to the Board. At a minimum, the Board or governing authority should receive the information that is provided in training and details of how the training is in administered.
As well as exploring these topics, Eric also answers:
- How often should the Board receive training?
- How should Board training be accomplished?
When training your Board of Directors, you should address the three pillars in board training: risk specific topic, regular review of the Board’s responsibility to oversee the compliance and ethics program, and a comprehensive review of employees’ and other stakeholders’ code of conduct training.
At Equifax, JoAnn wears many hats, like many compliance professionals. She is the compliance subject matter expert for the business units at Equifax of mortgage, healthcare, insurance, data and analytics, mobile commerce, and new product innovation. JoAnn has worked in the financial services industry since working at a credit union during college. Before joining Equifax, JoAnn held role in compliance within the financial services industry, including at Bank of America and Cornerstone Bank. In this segment, JoAnn talks about her career journey. She also discusses the importance of compliance professionals to see themselves as a member of an organization’s team so that you gain credibility within your company. She also talks about future trends in the financial industry.
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