Who do you train? The importance of witnesses and helpers

Who do you train? The importance of witnesses and helpers

Joe Murphy – Compliance & Ethics Professional – January 2014

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It is time to plan for the compliance and ethics training. Maybe it is privacy, or antitrust, or anti-corruption. Your job now is to determine who gets the training. Let’s say you have read my editorial on top executives, so you know you need to train them. You need to train the board on the risks they may create. And in each risk area, you know who is a poten- tial wrongdoer. You are developing your list and planning how to proceed, but have you missed one angle?

We can gain important insights from looking around the world at other standards for compliance pro- grams. Here is a relevant one from the Canadian Competition Bureau. The Bureau, in its guidance on compliance programs, calls for training “for staff at all levels who are in a position to potentially engage in, or be exposed to, conduct in breach.” The wisdom here is the reference to those who may “be exposed to” violations. 

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