The Department of Justice and Securities and Exchange Commission frequently drop nuggets of information as to their Foreign Corrupt Practices Act compliance expectations.
For instance, in this speech the DOJ’s Principal Deputy Assistant Attorney General talked about tailored FCPA compliance, tone at the top, and the importance of local language training.
In the Goodyear enforcement action, the SEC was complimentary of the company’s FCPA compliance improvements including an expansion of “on-line and in-person anti-corruption training for subsidiary management, sales, and finance personnel.”
In the Bruker enforcement action, the SEC chided the company for not translating FCPA training presentation into local language, including Mandarin. Similarly, in the Orthofix enforcement action the SEC noted that the company provided FCPA training but criticized the company because the training was only in English and therefore “it was unlikely that [subsidiary] employees understood them as most [subsidiary] employees spoke minimal English.” Indeed in the FCPA Guidance the DOJ/SEC state: “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.”
General counsel, compliance officers, and other corporate professionals should follow these enforcement agency nuggets to a best-in-class online anti-bribery training course.
The course is one I developed with Emtrain (an innovative compliance training company) and numerous companies across industry sectors have already selected it for their on-line anti-bribery training needs.
As to those enforcement agency nuggets, the approximate 60-minute course features:
- Executive and non-executive versions;
- The ability to configure the course with company-specific messages and videos from corporate leaders, company specific policies, and company employee hotline or reporting information;
- 20+ video clips that engage learners and illustrate real-world business scenarios that present risk ;
- Availability in the following languages: English, Spanish, Portuguese, Chinese (simplified), Japanese, French, Russian and others available upon request.
- 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.
To preview the course, use the below button.
