Mark DoroszVP of Compliance

LearningNew York, USA

Matt PlassChief Learning

OfficerBrighton, UK

How to design training for

AB 2053

California Anti-

Harassment Legislation

2-hours of workplace harassment training to be completed every two years by all people supervisors

Newly hired or promoted managers must be trained within 6 months

Training must be interactive and include “practical examples”

California law is commonly held up as the national standard, allows the 2-hour seat time to be broken into shorter and more meaningful learning chunks

What does the California law require?

Addition of requirement to train on “abusive conduct”, as well as unlawful harassment

You need to distinguish between “unlawful harassment” and “abusive conduct”

There is no guideline as to how much of the 2-hours should be devoted to one or the other

What changed on 01 Jan 2015?

Connecticut – 2 hours on sexual harassment within 6 months of hiring

Maine – requires all employees to take sexual harassment training, no guide on duration

Other states where Harassment training requirements for certain types of employee e.g. employees of the State:FloridaIllinoisIowaMichiganNevadaNew MexicoNorth Carolina

OklahomaPennsylvaniaTennessee TexasUtahWashington

Are there similar laws in other states?

We have a captive audience for 2 hours

How can we make the best use of this time?

Attestation

Impact

Investigation

Culture

Assembly

5 ways to make a difference in your 120 minutes of training

Idea #1: Assembly

What is Harassment and Discrimination?Impacts of DiscriminationTypes of DiscriminationSexual Harassment Preventing Workplace BullyingRetaliationProtected GroupsIntent vs. PerceptionSocial Media Risks for A-H&D

What is Workplace Conduct?Business EthicsInclusive WorkplaceInclusive ManagerViolence in the WorkplaceSubstance MisuseGifts & EntertainmentConflicts of InterestDiversity

What is important this year?

Assembly

Idea #2: Culture

1. Speak with authority

2. Facilitate difficult conversations

3. Promote the culture of compliance

4. Model behavior

5. Create a speak-up environment

Manager Focus

Break content down into short, digestible chunks

Focus on behaviour change

Teach values and principles to abide by

Align training with your workplace culture

Make learners complete 2 hours in one sitting

Teach the specifics of the law – information overload!

Exclude senior management from the development process

View it as a box-checking exercise

Encourage proactive strategies to anticipate compliance breaches Culture is not a set of

rules and regulations

DO DON’T

Idea #3: Investigation

1. Policy hunt

2. Investigate good ethical behavior

3. Explore corporate policies

4. Investigate regional and role-based differences

5. Uncover war-stories

Investigation

Idea #4: Impact

Present new concepts

Test for understanding

Practice to make it real

Attest to readiness

Our Instructional Model

1. 83% say yes to video!*

2. The inside track

3. Gone in 60 seconds

4. Tips from the top

5. Legitimacy with audience

*trainingzone.co.uk

Animations/Videos

1. Your people, your words

2. Your policies

3. I’m not a criminal!

4. Explore the grey areas

5. Play safe

Customization

Idea #5: Attestation

1. Are you ready?

2. Behavior checklist

3. Take responsibility for my actions

4. Award completion

5. Customized statements

Attestation

What is IS doing?

What is Interactive Services doing?

Anti-Harassment And Discrimination (A-H & D)

What is Harassment and Discrimination?

Impacts of Discrimination

Types of Discrimination

Sexual Harassment

Preventing Workplace Bullying

Retaliation

Protected Groups

Intent vs. Perception

Social Media Risks for A-H&D

“Got It” Taking Action on A-H&D

Workplace Conduct

What is Workplace Conduct?

Business Ethics

Inclusive Workplace

Inclusive Manager

Violence in the Workplace

Substance Misuse

Gifts & Entertainment

Conflicts of Interest

Diversity

“Got It” Taking Action on Workplace Conduct

1. Choose topics from existing library

2. Identify which ones are ready to go and which ones you want to customize

3. Workshop customization with partner and SME team

4. Partner implements customization

5. Launch

Here’s how Interactive Services is doing it

Customizing Your CLC Solution

Pick from 60+ Topics

4 weeks5 weeks

6 weeksRapidSmart

Managed

Build Your Topics Branding

Policy links

Splash screens

Add new screens

Add your imagery

Change the script

CLC Workshop

<Model Text>

We’re Counting on You

Our global clients, stakeholders, and investors count on us to conduct business with the highest ethical standards.

The good news is that at Gallus Retail we believe it’s simple to stay on the right side of Insider Trading Policy. Janine Smith, our Chief Compliance Officer, advises three simple steps:

If you see a breach of standards, or realize you’ve made a mistake, speak up immediately.

If you’re not sure, consult the Insider Trading Policy.

If you’re still not sure, speak to your manager or contact the compliance helpline.

1 x 720p MP4 executive video message not to exceed 120 seconds

1 x Uncompressed JPEG, PNG or Tiff image at least 3000px by 2000px

Instructional Tips For Compliance OfficersThis screen helps learners make the connection between your firm’s Insider Trading policy and their personal responsibility. Keep the message simple, under 200 words and try to include three memorable steps every employee can take.

Sample Customization Worksheet <T1:S2>

Insider Trading

What is Insider Trading?

Consequences of Insider Trading

Material Non-Public Information

Tipping

"Designations, Restrictions & Trading Windows"

“Got It” Taking Action on Insider Trading

Anti-Money Laundering

What is Money Laundering?

Consequences of Money Laundering

Placement Layering, Integration

Tactics to Prevent Money Laundering

The Risk Lifecycle

Sanctions and Embargos

Internal Reporting for AML

“Got It” Taking Action on AML

Anti-Harassment And Discrimination

What is Harassment and Discrimination?

Impacts of Discrimination

Types of Discrimination

Sexual Harassment

Preventing Workplace Bullying

Retaliation

Protected Groups

Intent vs. Perception

Social Media Risks for Harassment & Discrimination

“Got It” Taking Action on Harassment & Discrimination

Workplace Conduct

What is Workplace Conduct?

Business Ethics

Inclusive Workplace

Inclusive Manager

Violence in the Workplace

Substance Misuse

Gifts & Entertainment

Conflicts of Interest

Diversity

“Got It” Taking Action on Workplace Conduct

Information Security

What is Information Security?

Consequences of an Information Security Breach

Email and Messaging

Welcome1 is not a Password

Secure Social Media

Secure Workstation

Secure Outside the Office

Social Engineering

“Got It” Taking Action on Info Security

Data Privacy

What is Data Privacy?

Protecting Personal Information

HIPAA Basics

Working with the Cloud

Storing Data

Disclosures

“Got It” Taking Action on Data Privacy

PCI DSS

What is PCI DSS?

Sensitive Data & Vulnerable Areas

Handling & Storing Data

Preventing Breaches

Got It! Taking Action on PCI DSS

Anti-Bribery & Corruption

What is Anti-Bribery & Corruption?

Consequences of Bribery & Corruption

Bribery & Corruption High Risk Activity

Cash, Gifts, Entertainment and In-Kind

Tactics to Prevent Bribery & Corruption

Books & Records

Politically Exposed Persons

Red Flag Locations

“Got It” Taking Action on A-B & C

Anti-Trust

What is Anti-Trust?

Dealing with Competitors

Dealing with Customers

Communication & Document Creation

Got It! Taking Action on Anti-Trust

Build Your Solution From 3 Libraries and 60 Essential Topics

LANGUAGE PACK (Arabic, French, German, Italian, Japanese, Standard Chinese, Polish, Portuguese, Russian & Spanish)

1. Culture is habit forming

2. Impact, preparing for tomorrow

3. Take responsibility through personal investigation

4. Mix and match what’s important to you

5. Attest with confidence

5 key points to remember….

Interactive Services will be running a series of short executive briefings for interested companies in April and May.

Please let us know if this you’d like us to arrange one specific to your firm.

What happens next?

Mark Dorosz (mdorosz@interactiveservices.com)VP, Compliance LearningNew York, USA

Matt Plass (mplass@interactiveservices.com)Chief Learning OfficerBrighton, UK

Neil Cullen (ncullen@interactiveservices.com)Director, Compliance LearningNew York, USA