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The LRN ethics and compliance risk management practices report

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KEY FINDINGS<br />

To address these concerns, companies need to develop comprehensive privacy <strong>and</strong> security<br />

policies; conduct audits of their data <strong>practices</strong> including Internet activities, cross-marketing<br />

<strong>and</strong> data sharing with affiliates <strong>and</strong> partners; manage their internal data usage, such as<br />

h<strong>and</strong>ling of customer <strong>and</strong> employee personal data; <strong>and</strong> educate employees to prevent<br />

breaches or losses related to data privacy.<br />

A majority of companies perform formal <strong>risk</strong> assessments involving multiple<br />

functions<br />

Respondents are taking <strong>risk</strong> assessment seriously, with nearly 9 in 10 respondents indicating<br />

they perform <strong>risk</strong> assessments regularly. Slightly more than half say they integrate <strong>ethics</strong> <strong>and</strong><br />

<strong>compliance</strong> concerns into other business assessments. Results indicate that depending on<br />

the nature of the <strong>risk</strong>, companies are utilizing one or more of the following departments in<br />

their <strong>risk</strong> assessments:<br />

• <strong>compliance</strong>,<br />

• legal,<br />

• internal audit, <strong>and</strong><br />

• human resources.<br />

Most importantly, two-thirds of respondents share the findings of the <strong>risk</strong> assessments with<br />

their Board <strong>and</strong> their senior executives, ensuring that top leadership participates in the<br />

responsibility for building ethical <strong>and</strong> law-abiding business conduct. Furthermore, almost<br />

one-quarter also share their findings with employees, thereby reinforcing ethical awareness<br />

<strong>and</strong> demonstrating the company’s commitment to fostering an ethical workplace.<br />

Only 4 in 10 respondent companies involve their business managers in the <strong>risk</strong> assessment<br />

process. <strong>The</strong> middle <strong>management</strong>s’ proximity to operations enable them not only to have<br />

a more in-depth knowledge about where the <strong>ethics</strong> <strong>and</strong> <strong>compliance</strong> challenges may lie<br />

but also to gain the subordinates trust <strong>and</strong> become the channel of choice when <strong>report</strong>ing<br />

a potential violation. Not tapping into these two key advantages of middle <strong>management</strong><br />

creates a critical gap in the <strong>risk</strong> assessment <strong>and</strong> detection processes. Furthermore, the survey<br />

results indicate that nearly all companies want supervisors to be a channel for employees to<br />

<strong>report</strong> violations, it is counterproductive to not involve them in the <strong>risk</strong> assessment process.<br />

Companies would benefit significantly by proactively including managers in every step of<br />

the <strong>risk</strong> <strong>management</strong> cycle <strong>and</strong> could substantially improve employees’ willingness to <strong>report</strong><br />

violations to managers.<br />

Companies cite engaging employees <strong>and</strong> making education more relevant as their<br />

top challenges in prevention<br />

In terms of preventing <strong>risk</strong>, respondents point to a lack of resources as their leading<br />

challenge, with nearly 6 in 10 companies marking it. However, beyond this perennial<br />

problem, the next two leading challenges reflect crucial factors that make or break getting<br />

employees motivated to take <strong>risk</strong> <strong>management</strong> personally: relevancy <strong>and</strong> engagement.<br />

More than 4 in 10 respondents indicate making the education relevant is their next most<br />

significant challenge, <strong>and</strong> one-quarter cited engaging employees.<br />

<strong>The</strong> search for relevancy <strong>and</strong> engagement is critical in <strong>risk</strong> prevention. <strong>The</strong> learning theory<br />

states that adults pay less attention to information that does not directly affect their<br />

jobs than they do to information that has an immediate value to their day-to-day work.<br />

Numerous studies have also shown that engaging people in their learning boosts their<br />

interest in <strong>and</strong> ability to use the knowledge. Learning resources that allow people to control<br />

their own progress, interact with the materials, <strong>and</strong> gauge their learning through self-tests<br />

have proven to have higher impact on adults than one-dimensional lessons that workers<br />

passively read or listen to.<br />

<strong>LRN</strong> | 2008 Ethics <strong>and</strong> Compliance Risk Management Practices Report | 7

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