What are some of top Board-level metrics that you use to communicate the effectiveness of the Ethics and Compliance program?
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Head, E&C Transformation, Training & Communications in Healthcare and Biotech6 months ago
What benchmarks are you using for E&C Training, specifically on-time completion rates?
1) Compliance training program completion rates by division, category, and also pass rates for those courses where there is a proficiency test. These will tell you how effective your training is, and where in the organization you may have hot spots to focus on;
2) Reporting rates, by channel (ethicsline, HR, etc) such as: a) potential conflicts of interest, b) observed misconduct, by channel, and substantiation rates, c) gifts and entertainment d) privacy incidents, e) code of conduct and policy violations ;
3) Integrity Survey results - which asks specific questions about awareness of and comfort with various reporting channels (including the C&E function), observations of misconduct, trust in manager, leadership, etc. If you are in highly regulated industries, you would also track things like customer complaints and the complaint ratios over time, regulatory exam/audit findings, licensing rates (if certain employees require licensure), implementation rates of new laws and regulations.
Wherever you see gaps or red flags, you would put that on your plan for deeper dive risk assessment and mitigation, and measure success based on progress and effectiveness of any new or upgraded controls in those areas.
Typically you will provide very high level reporting on the above, and provide more detailed reporting for business unit management so they can have visibility and can be held accountable for issues they own. While this illustrates how effective the C&E program is, it will require partnership with business unit leadership to drive results.