- FCPA Professor - http://fcpaprofessor.com -

The Importance Of Local Language Training

It is a basic fact that training is an essential component of an effective corporate compliance program.

As it relates to the FCPA, the DOJ/SEC state in the FCPA Guidance [1]:

“Compliance policies cannot work unless effectively communicated throughout a company.  […]  Information should be presented in a manner appropriate for the targeted audience, including providing training and training materials in the local language.”

Compliance issues that can arise from not training employees and business partners in a local language was best highlighted by the FCPA enforcement action against Orthofix International.  (See here for the DOJ action, here for the SEC action).  The conduct at issue concerned the company’s wholly-owned subsidiary in Mexico and payments made by the subsidiary.

Regarding the deficient internal controls of Orthofix, the SEC stated:

“Orthofix did not have an effective FCPA compliance policy or FCPA-related training.  Although Orthofix disseminated some code of ethics and anti-bribery training to [the subsidiary employees], the materials were only in English, and it was unlikely that [subsidiary] employees understood them as most [subsidiary] employees spoke minimal English.”

The new Global Anti-Bribery and Corruption Training Course I have released with Emtrain [2] (an innovative compliance training company) addresses the language gap that can derail effective compliance by offering the course in the following languages: Spanish, Portuguese, Chinese (simplified), Japanese, French, and Russian.

In other words, the Global Anti-Bribery and Corruption Training Course allows a company to most effectively communicate its commitment to FCPA and related compliance – as well as the company’s specific compliance policies and procedures – no matter if a company’s agent is located in Mexico City; a distributor is located in Sao Paulo; a joint venture partner is located in Shanghai; a sales representative is located in Tokyo; a business partner is seeking a deal in Kigali; or a subsidiary is expanding in Moscow.

The foreign language versions of the Global Anti-Bribery and Corruption Training Course contain the same unique aspects of the originally released English language course.  Among other things, the approximate 60 minute online course features:

  • Executive and non-executive versions
  • The ability to configure the course with company-specific policies, videos, graphics, text, and employee hotline or reporting information
  • 20+ video clips to illustrate real-world business scenarios that present risk
  • An Enforcement Risk Spectrum that helps learners “issue spot” bribery and corruption risk
  • The ability to use video scenes outside the e-Learning experience in live training, discussion groups, or company emails and reminders
  • A compliance Learning Management System enabling an administrator to launch and track training efforts and generate audit-ready training reports showing time spent on each video, screen, policy, etc.

To see what others are saying about the Global Anti-Bribery and Corruption Training Course, see here [3].

To preview the course, use the below button.  (At the bottom of the start screen is a drop-down menu that is pre-set to English.  Click and it will say “select desired language”).
 
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