Compliance Training Challenges

Source: IT Business Edge | Priority: Managing Compliance Standards | Topic: Sarbanes-Oxley
Date Published: 9/15/2005

With Sanjay Anand, chairperson of the SOX Institute. Anand is a globally recognized compliance, risk management and business process consultant, professional speaker and published author.

Question: What training challenges do companies face when it comes to Sarbanes-Oxley compliance?
Anand: One challenge many companies face is that some executives don't think they need Sarbanes-Oxley training. Many think they can wing it and don't have to go through a formal training program. Once they get past that, they don't often still know who they need to train, whether (it should be) executives, managers, project leaders or everyone involved in the implementation. Another challenge companies face is that they have a hard time allocating sufficient budgets to training. It's a question of either paying now or paying later, and many are opting to pay later. They think they can go back later and fix what they did wrong. Finding the time to train is also pretty difficult for many companies.

Question: How do companies decide whom to train?
Anand: The key to training is to do a job analysis to determine what training is relevant to whom. You have the executive level, project managers and leaders, and the hands-on people who do the documentation and implementation. You also have several disciplines involved, including finance, accounting, IT, ethics and legal. So with the various disciplines and levels, you draw a matrix to identify who in the organization needs to attend which program. We recommend that C-level executives stay at the C-level; they don't need a hands-on workshop. Those working on Section 404 documentation processes need to understand what the requirements of Section 404 are from an implementation standpoint. It's important to avoid overkill because there's no need for it. Organizations don't need to be training more people than they need to.

Question: What roles do corporate leadership and the corporate code of conduct play in making a company compliant?
Anand: The leadership sets the stage and the ground rules on how an organization is to behave. The leadership has to set the right example of ethics, integrity and honesty by making it clear that these values must be prevalent throughout the organization in order for it to meet compliance objectives. Another value is transparency. Compliance is intended to introduce transparency to business processes. This can occur only if the top level is clean. The other side of the equation is that a code of conduct empowers employees to do the right thing without having to micromanage them. Without such a code, the tendency is to micromanage to try to control the outcome. With a code, there is a guiding light, something that says who we are, this is what we believe in, and this is how we behave.
A good compliance initiative has the leaders managing the process and not the people. If the process is properly managed, the people will actually follow. One may argue that not all will follow, which is true. The reason you need the process is to handle discrepancies, so it's always about the process. This is communicated through the corporate code of conduct. It sets up consistent expectations so that you don't have to manage every fine detail of employee behavior. Instead, you can trust people to work together to achieve a common objective. This trust can come from a well-written corporate code of conduct.
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