Download It Takes Lots of Hard Work: Developing, Promoting and Growing

It Takes Lots of Hard Work:
Developing, Promoting and Growing Your
Compliance Program
Jackie Phillips
VP, Corporate Ethics and Compliance Officer
Bill Brown
Director, Ethics
and
Ethics
andCompliance
Compliance |
Covered In This Session
• Who is Spectra Energy?
• Requirements of an effective ethics and compliance program
• How Spectra Energy successfully used compliance training as a key component in
our strategy to develop, promote and grow our compliance program
–
Building awareness through coordination and alliances
–
Enhancing employee engagement and better resource utilization
–
Focusing on personal accountability and connecting our compliance responsibilities to
day-to-day work
• Challenges facing ethics and compliance practitioners
• Benefits of bringing training and compliance culture to life
Ethics and Compliance | 2
Who is Spectra Energy?
Spectra Energy is a premier North American pipeline and midstream company
Headquartered in Houston, TX with more than 8,500 employees and contingent workers
• Operations in the US and Canada
–
21,000 miles of natural gas, natural gas liquids and crude oil pipelines
–
~300 Bcf of natural gas storage, natural gas gathering and processing
–
Local distribution company serving 1.5+ million customers in Ontario, Canada
• Currently executing an aggressive growth strategy:
–
Secure $35 billion in new growth projects by the end of the decade
• Is in transition to merge with Enbridge by end of first quarter in 2017
Ethics and Compliance | 3
1
Where Spectra Energy Fits In
The Energy Value Chain
Natural
Gas
Natural
Gas (Liquids)
Crude
Oil
Ethics and Compliance | 4
Strategically Located Asset Footprint
Connecting Supply to Demand Markets
Ethics and Compliance | 5
Elements of the U.S. Federal Sentencing Guidelines
Application Tailored to Individual Organization
Meet the requirements for an effective program.
• Exercise due diligence to prevent and detect criminal conduct
• Promote an organizational culture that encourages ethical conduct and a commitment
to compliance with the law
–
Standards and procedures
–
Monitoring, auditing and evaluation
–
Three levels of compliance program
oversight
–
Consistent enforcement and appropriate
incentives
–
Diligence to ensure management has
not engaged in misconduct
–
Appropriate response to violations
–
Communication and training
Ethics and Compliance | 6
2
Minimum Effort May Increase Risks of Non-compliance
Go Beyond Base Level Requirements
High performance organizations go beyond the threshold legal requirements to
strengthen the culture of ethics and compliance. They set the standard and tone
for others to follow.
• Promote ethical business standards and practices internally
• Enable managers and employees to make good choices
• Shape future industry standards by producing tomorrow’s best practices today
A strong culture of ethics and compliance everywhere helps to mitigate risks,
enhance safety and provides value to stakeholders.
Ethics and Compliance | 7
The Strategy We Used To Grow Our Program
Our Compliance Training Journey
Increasing Our Organizational Impact/Effectiveness
HIGH
PERFORMANCE
• Our License to Build
& Operate
• Enhancing Personal
Accountability
• Employee Engagement
• Effective
• Building Awareness
• Better Resource Utilization
• Coordinated
• Connected
• Uncoordinated
• Standing Up Organization
COMPLIANT
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
Ethics and Compliance | 8
Change the System and Make It Better
Move the Needle with Every Project
Good, smart, streamlined compliance training adds value for directors,
management, workers and other stakeholders.
• Engage board, management and
• Elevate the culture of ethics and
workforce and drive compliance culture
compliance
at every level
• Reduce impact on organizational
• Provide senior management with the
productivity
opportunity to be more engaged in the • Enable collaboration among internal
process
compliance groups
• Demonstrate strong organizational
commitment to compliance
• Aid employees understanding about
their compliance responsibilities; make
better compliance decisions
Ethics and Compliance | 9
3
Standing Up the Organization
Jan 2007 - Dec 2009
January 1, 2007 Spectra Energy became an independent company and
established its own ethics and compliance program. Full implementation of
the program continued for two years.
• Initial code of business ethics (CoBE) a flat Word document without images
• CBT module (2007) similar to CoBE; it didn’t include voiceover
• Ethics and compliance engaged vendor (2009) to develop a scenario based CBT
module. The results:
–
High costs and limiting given we were
‘only licensed’ to use our own content
–
We observed the vendor and learned
the development process as it unfolded
–
Quickly learned not to like this business
model
–
We gained confidence to develop our
own custom course
Ethics and Compliance | 10
Building Awareness and Coordinating Activities
Jan 2010 - Dec 2012
By 2010 the Ethics and Compliance Group was earnestly developing the program.
Achieved too is the coordination and streamlining of compliance training activities.
• Made case for executive management buy-in and financial commitment for the compliance
building strategy
• Enlisted executive management participation into live training
• Delivered hard-copy revised CoBE to all employees; revised EthicsLine posters
• Established compliance training team
• Branded iComply training program; created compliance intranet page
• Developed Compliance Week training project
• Utilized humorous videos to supplement training concepts
Ethics and Compliance | 11
Building Awareness and Coordinating Activities
Jan 2010 - Dec 2012
• Incorporated comedic talent into live training sessions
• Utilized branded collaterals at live training sessions (hand-held clappers, pens, posters, brochures
and other give-a-ways
• Incorporated game show format into CBT and live training sessions
• Awarded prizes (iPads and gift cards) for timely training completion
• Created compliance videos and slideshows stressing personal accountability and awareness
–
Spectra Energy collaborated with an outside vendor creating FERC compliance video content
available for use anywhere in the industry.
• Created new Compliance intranet site on employee portal
• Deployed ‘compliance in a box’ to regional offices
• Created periodic communications - iComply Minute; and iComply at the movies.
Ethics and Compliance | 12
4
Expanding Employee Engagement & Better Resource Utilization
Jan 2013 – Dec 2015
From 2013-15 we sharpened the message and expanded collaboration with other
groups. Senior management involvement helped drive higher employee
engagement and make a deeper connection to compliance.
• Developed vision, purpose and compliance commitments statement for Company
–
Chief Ethics and Compliance Officer emailed statement and compliance message to managers
• Developed specific compliance training for managers
• Allowed employees ability to individually customize training via ability to complete core and
elective training courses
• Expanded number of live training sessions and number of locations visited
• Targeted messages to managers encouraging them to lead by example, use available training
tracking tools, and understand their responsibilities
Ethics and Compliance | 13
Expanding Employee Engagement and Better Resource Utilization
Jan 2013 – Dec 2015
• Developed an iComply Training Dashboard to encourage employees to go beyond minimum
training standards and complete higher level courses
–
Basic: Completion of mandatory training, and
annual attestation business conduct
questionnaire (BCQ)
Intermediate: Completion of basic level plus
participate in compliance or safety discussion
and respond to a questionnaire
Advanced: Completion of basic and
intermediate levels plus an LMS assigned
–
–
–
–
compliance or safety course during the training
period
Provided high-level recognition to individuals
going beyond basic training requirements
Monetary incentives awarded (random drawing)
only to individuals completing advanced level
course
• iComply Dashboard and incentives encouraged employees to complete other compliance and
safety courses assigned through LMS before respective deadlines
– This helped mitigate risks, strengthen compliance and safety culture
Ethics and Compliance | 14
Enhanced Personal Accountability, Connecting Compliance
Responsibilities & Our Business
Jan – Dec 2016
Employees compliance maturity grew and illuminated how their day-to-day
compliance responsibilities connected with our business. A generic long-haul
pipeline project development description showed our compliance and business
connections.
• Training refreshed to discuss compliance and our business
–
Pipeline project described in three buckets: certification, construction and operations
–
Live training designed to be highly interactive via a compliance conference
–
Conference and exhibits format allowed direct contact with subject matter experts
Ethics and Compliance | 15
5
Enhanced Personal Accountability, Connecting Compliance
Responsibilities & Our Business
Jan – Dec 2016
• Enhanced technology helped increase engagement and information retention
– iComply training app created to capture individual compliance training experience
– Training included augmented reality, videos and animation
– Virtual instructor (L.U.C.I. (luminescent user compliance interface)) guided trainees through
the app
LUCI provided: welcome message; pipeline development and operation; video instruction; exit
message and an actionable suggestion for taking personal accountability for safety and compliance.
Ethics and Compliance | 16
Improvement Takes Time and Lots of Collaborative Effort
Challenges Compliance Practitioners Face
These responses to a survey in 2010 by the Ethical Corporation on “Challenges
Facing Ethics and Compliance Executives” remain relevant in 2017
• Getting employee buy-in and commitment to true ethical behavior
• Getting support from top management and changing the view of compliance as a
mere cost center
• Fighting against the existing ‘turn-a-blind-eye’ culture, and the way ‘business has
always been done’
• Managing an effective compliance program in a resourced constrained environment
• Defining ‘adequate’ for your company’s compliance efforts, how do you know you’re
doing enough?
Ethics and Compliance | 17
Imagination, Commitment to Excellence, and Laser Focus
Bring Compliance Training & Culture to Life
Our ethics and compliance culture is a shared belief and experience which is
praised and referenced often.
• The audit committee often praises the program and demonstrates curiosity
• Executive management exemplifies strong tone at the top
• Senior and mid-level management engage in and encourage compliance for their
teams
• Employees cite values, Code and policies in both praise, criticism and hotline reporting
• Organization viewed as an industry leader
–
We believe regulators, communities and business partners trust us to do the right thing
Ethics and Compliance | 18
6
Reference Slides
Ethics and Compliance | 20
Promote Ethical Business Standards Internally
• Code of Business Ethics and company policies
are easy to read and easily available to all
employees on the Source
• Clear, observable and supportive tone at the top
• An engaged audit committee who expects to
receive regular updates, and intermittent ones
as needed
• An engaged workforce who demonstrate buy-in
to our culture of compliance, and an
understanding of their personal accountability
for compliance.
Ethics and Compliance | 21
7
Enable Managers and Employees to
Make Good Choices
• Maintain an open door environment which allows for
concerns to be raised without fear of retaliation
• An available hotline reporting system (EthicsLine) for
confidential and anonymous reporting
• Relevant, customized, compliance training that is continuously
refreshed, completed in collaboration with various compliance
centers, and has the support of key members of management
• Clear messages to employees about their compliance
responsibilities and how to get answers to questions/concerns
• Promote, monitor and test our compliance culture
Ethics and Compliance | 22
Shape Future Industry Standards By Producing
Tomorrow’s Best Practices Today
• Sit on boards of important industry trade groups such as INGAA,
NAESB and GHBER (Greater Houston Business Ethics Roundtable)
which serve to drive standards and culture
• Collaborate with vendors to produce and disseminate content for
use in the natural gas sector
• Share training practices among industry peers (at SCCE
conferences, for example)
• Require vendors, suppliers, contractors and JV partners to support
our compliance practices and also support compliance in their
respective organization
• Incorporate compliance requirements into our contracting process.
Ethics and Compliance | 23
Initial Ethics and Compliance Training (2007)
Completion Time Approximately Two Hours
• HTML based
• No voiceover
• Dull!
• Boring!
• Not effective!
Ethics and Compliance | 24
8
Updated Ethics and Compliance Training (2009)
Completion Time Approximately One-half Hours
• Scenario based
• Utilized flash player
• More inter-active
• Contained voiceover
• Housed in LMS
Ethics and Compliance | 25
Updated Code of Business Ethics
Ethics and Compliance | 26
New EthicsLine (hotline) Posters
Ethics and Compliance | 27
9
iComply
Training Team (2010)
Jackie Phillips, VP Ethics and Compliance (Project Manager)
Compliance Week Project Team
– David Belew, Records Management
– Kim Jackson, EHS US Operations
– Riva Bonner, Diversity and Community Relations
– Rohby Mitchell, Employee Relations
– Bill Brown, Ethics and Compliance
– Shawntae Nix, FERC Compliance
– Peter Chung, Training and Development
– Dominic Sack, Internal and External Affairs
– Glen Dally, IS Business Applications
– Charles Shaw, Talent Management
– Gord Doermer, Enterprise IT Security
– Veronica Sweeney, EHS Governance
– Connie Durouso, Ethics and Compliance
– Courtney Forbes, Canada IT Security
– Erika Young, ETNG Marketing and Business
Development
– Tom Hall, FERC Compliance
– Delores Zappala, HR Employee Relations
Ethics and Compliance | 28
Compliance Training Logo
Ethics and Compliance | 29
Compliance Intranet Page
Compliance Intranet page on the
Source is a landing page to access
online compliance related
material within the organization
Ethics and Compliance | 30
10
Prior To Coordination Separate Trainings Depressed Productivity
Coordinated Training Enhances Productivity
Chaos; Confusion; Frustrating
Order; Clarity; Pleasant
Ethics and Compliance | 31
Humorous Supplemental Training Videos
Training Day: Market Manipulation
Idle Chit-Chat: No Conduit Rule
Ethics and Compliance | 32
11
Compliance Week Description (2013)
Ethics and Compliance | 34
Chief Ethics and Compliance Officer
Message to Managers (2013)
Ethics and Compliance | 35
iComply Dashboard (2013)
Ethics and Compliance | 36
12
Enhanced Training Demonstrates
How Spectra Energy Does Business “The Right Way”
Certification is one of the first
steps needed to bring an asset
online. Topics discussed:
•
Educate landowners and
stakeholders about
pipeline project
•
Environmental Impact
Statement and how we
minimize impact to
landowners & the
environment
Compliance is deeply
embedded into the
construction of our pipeline
assets, which helps maintain
our strong safety record. Topics
discussed:
•
Conduct civil surveys to
mark construction of rightof-way
•
Respect the property rights
of landowners
•
Right-of-way agents adhere
to laws and SE values
•
Building smart, safe and in
compliance
•
Building on time and in
budget
•
•
Dealing with public
opposition to pipeline
projects
•
•
Understanding regulatory
requirements (FERC; OEB &
NEB)
•
•
Sensitive and confidential
information
•
Spectra Energy operates
natural gas, natural gas liquids,
and crude oil pipelines; natural
gas storage; crude oil storage;
natural gas processing, and
local distribution operations.
Topics discussed:
•
Engage IT Security to
ensure information
security is considered at
start of a project
•
Pipeline operation and
compliance with regulatory
requirements
•
Our integrity management
program and industrial
controls systems
Above all else we keep
ourselves, teams and
communities safe
•
Meeting customer
demands during peakusage periods
Ensure construction
records retained according
to retention schedule
•
SE environment safe and
free from harassment,
opportunity to develop,
values clear open
communications
•
SE reputation of safety and
reliability rests on our
compliance commitment
Create a safe, efficient
construction site by
clearing the area of debris,
grading land and installing
erosion control devices
Stop work if a situation
becomes unsafe; you must
report incidents ASAP
Ethics and Compliance | 37
Compliance Conference Attendees Excited
About Format and High-Level Of Interaction
iComply Compliance Conference sessions in Houston
and Chatham:
• General Session included panel discussion by subject matter
experts who included content within the training module
• Conference exhibits provided direct interaction with subject
matter experts
– Trainees rotated by assigned group to 10 stations
Certification; Business Ethics; HR Compliance; IT Security;
Construction; Regulatory; Records Management; Operations; EH&S;
Business Conduct Questionnaire
– Was used to train 887 employees and contingent workers
Ethics and Compliance | 38
Using Enhanced Technology Increases Employee
Engagement And Retention
Developed Spectra Energy iComply training
app which:
• Captured trainee’s compliance training experience
and responses to the business conduct
questionnaire
• Included augmented reality, videos and animation
Nine (9) new videos created
• Was loaded to rented iPads for live training sessions
• Segmented each topic area into 10-minute
discussion points
• Did not interface with Spectra Energy IT systems in
conformance with IT Security requirements
Ethics and Compliance | 39
13
Virtual Instructor Surprised And Interested
Employers Who Asked For More
Created a virtual instructor to guide trainees through
the Spectra Energy iComply training app and online
training module. LUCI provided the augmented reality
portions to:
• Welcome message and information about the training
• Specifics about the Certification process and video showing
Spectra Energy workers
• Specifics about the Construction process and video
showing Spectra Energy workers
• Specifics about the ongoing Operations processes and
video showing Spectra Energy workers
• Exit message with focus on personal accountability for
compliance
Ethics and Compliance | 40
14