CPA Global: Compliance Learning Investments
Compliance Needs and Drivers
CPA Global supports many of the world’s largest corporations and law firms with a range of IP and broader legal services. The company focuses on assisting in the management of IP risk, cost, and capacity to help organizations realize greater value from their businesses and IP assets. It has 20 offices located in 10 countries and territories spanning the United States, Europe, and Asia Pacific to serve clients in 200 jurisdictions. While the company focuses on IP needs, it also offers services relating to e-discovery, mergers & acquisitions, and anti-bribery and compliance.
CPA Global’s compliance department faces considerable complexity resulting from its global footprint and activities across a large number of jurisdictions. It is subject to multi-jurisdiction trade laws, local regimes, and the extra-jurisdictional reach of laws such as the U.S. Foreign Corrupt Practice Act (FCPA) and the U.K. Bribery Act 2010. This creates a complex and sometimes contradictory array of requirements depending on the geographic location of the company’s activities. Further, employing over 1,700 employees, the company also confronts a great deal of organizational complexity in its compliance management efforts.
Nonetheless, the company reports that its core compliance drivers are its customers. In particular, the company cites customer scrutiny regarding export control, sanctions, and anti-bribery compliance. The company recognizes that its ethics and standards protect not just its own organization but its clients as well. For this reason, it gives a tremendous degree of attention to its ethics program. This has lead to a strong reputation for compliance investments, which it views as a market differentiator. This reputation has proven increasingly important, as the company has observed increasing attention to compliance risk among its customers. In fact, the company reports that ethics standards requests have appeared with greater frequency in requests for proposals (RFPs) and vendor due diligence questionnaires, prompting continuing focus on the impact on its compliance programs.
“Everyone should be aware of the things they should do and what they shouldn’t do. This is especially important with topics like anti-bribery. You never know what information one might hear or come across. We want everyone ‘on notice.’ If you have everyone go through compliance requirements, they all gain the ability to spot issues and raise red flags when needed.”
- Mark Speck Head of Global Audit and Chief Compliance Officer, CPA Global
Compliance Program Overview
Due to the factors described above, CPA Global places a premium on the quality and efficacy of its compliance operations. It places special emphasis on anti-bribery, Know Your Third Party, and the development of ethics best practices. The company sets a high standard of behavior for all employees and suppliers. There are three core aspects to how the company achieves its standards: its code of conduct, training initiatives, and whistleblower support program.
Code of Conduct
Like many organizations, CPA Global’s Code of Business Ethics and Corporate Conduct lies at the heart of its ethics program. Codes of conduct set basic policies and standards for employee behavior. CPA Global’s code is not different in this respect, but does stand out in its breadth. It goes beyond basic business ethics and client confidentiality to also include policies related to anti-bribery, gifts and entertainment, conflicts of interest, insider trading, and whistleblower standards. Where in some organizations, subjects like anti-bribery might be the subject of a standalone policy communicated only to “high risk” employees, CPA Global found that it was valuable to ensure that all employees were educated on these policies. The goal is to make all staff partners in company ethics to prevent the risk that misconduct goes unnoticed.
CPA Global builds on the inclusive philosophy undergirding its code of conduct in its approach to training. Here, the company emphasizes accessibility and engagement of its training content to help ensure that staff retain, appreciate and internalize standards. The company uses an online training platform that allows employees to access training content as they need it. In order to help promote engagement, the company uses a library of short, interactive videos, emphasizing targeted communication over longer “talking head” videos.
If the code of conduct and training elements of CPA Global’s ethics operations are intended to set and communicate standards, its whistleblower program is intended to provide employees with the ability to safely report violations. As such, the company prioritizes employee reporting confidence and concerns over retaliation. It has a whistleblower phone hotline and online reporting tool provided by NAVEX Global that permit anonymous or identified feedback based on the employee’s comfort level. The company also possesses a strong non-retaliation policy to ensure that whistleblowers are protected. As long as an employee comes forward without malice, the company provides that no adverse action may be taken against him or her as a result of the use of the program.
This degree of “safety” is important. Internal whistleblower programs provide organizations with the ability to identify and address compliance risks at very early stages. This helps reduce the cost of noncompliance by early remediation as well as providing demonstrable evidence to regulators and government agencies that a company has taken appropriate action to prevent issues. Employee trust is critical to the success of these programs. Many organizations provide hotlines and whistleblower options but with little impact due to employee concerns about retaliation. To demonstrate this trust, the company notes that all reports to date have been made directly to its compliance officers, with only one whistleblower requesting anonymity. By addressing these concerns, CPA Global helps ensure that its whistleblower options provide value to the organization.
“One of the most important aspects of the programs was to ensure that the training was engaging. It needed to be entertaining. It also had to be interactive. Above all, it needed to resonate and help employees apply lessons effectively. This was a key factor when deciding on the training provider.”
- Mark Speck Head of Global Audit and Chief Compliance Officer CPA Global
Other Aspects of the Compliance Program
In addition to the three aspects listed above, CPA Global has made investments in its ability to maintain an ongoing program of third-party risk due diligence in support of its anti-bribery initiative, and global economic sanctions. It uses the results to maintain its own compliance as well as to notify clients of potential changes that may affect them.
Further, in order to expand its program without increasing costs, CPA Global uses a compliance officer volunteer program. This program involves the use of qualified individuals within the company, usually attorneys, who devote extra time to specific risk-based objectives. The company reports that this program helps expand the scope of its compliance activities and builds support within business units. Currently, two volunteers accompany the company’s two dedicated full-time compliance employees, expanding the department’s capacity significantly.
Compliance Learning Investments
Training represents a critical portion of CPA Global’s compliance program. While its code of conduct sets company standards and its whistleblower program offers a safety valve for identifying compliance risks, its training program fulfills the critical function of setting and encouraging the proper behavior. An effective training program helps promote organizational compliance risk in three ways:
- reducing opportunities for unknowing violations
- identifying and incentivizing best practices related to known compliance concerns
- sensitizing staff to issues and warning signs so that they know when to raise red flags
Mindful of these dynamics, CPA Global pays close attention to its ability to engage employees in its content. It thus prioritized employee engagement and content accessibility to its compliance training program. To this end, the organization has deployed an online training platform, which allows the organization to deploy training content efficiently across the enterprise. A centralized, online platform permits employees to access content anywhere and as needed. This enhances employee convenience, allowing them to complete training on their time and location preferences. It was also a critical aspect of delivery, since the organization needed to be able offer easy access to relevant in-country requirements across global operations.
To provide superior engagement, the company uses short, interactive training content. It also relevant by including examples related specifically to CPA Global risk. Finally, by using interactive formats that question users over the course of the material, the company is able to provide immediate context to uses. To this end, the company does not require employees to replicate the “right answer,” but escalates scenarios to demonstrate the consequences of decisions. The result is a program that prompts users to think meaningfully about compliance issues, rather than learn rote answers with little real-world value.
In order to obtain these capabilities, CPA Global chose NAVEX Global to provide its training platform and training content. CPA Global previously selected NAVEX Global for its whistleblower hotline service and rolled both solutions out simultaneously to coincide with a revised policy release. Before selecting NAVEX Global’s online platform and training content, the company reviewed a series of vendors to find an offering that best fit its objectives, including resonance with its global corporate culture.
In both platform and content, CPA Global prioritized user experience in its selection process. To make these determinations, it tested content with employees, who provided feedback on which offering they found to result in the best learning experience by being the most engaging, and resulting in superior content retention. The company found that most products it reviewed were “too traditional,” offering video content that was not compelling. By contrast, they found that NAVEX Global’s platform provided an effective interface and customizable content that met these objectives.
As a final step, the company recognized that even with the most effective content, it would need to motivate employees to participate in training. To this end, they made use of the “tone at the top.” As such, they emphasized executive sponsorship of the training program. The company’s CEO Peter Sewell recorded a short video message emphasizing the importance of the ethics program and encouraging employees to complete the program in 30 days. This message was issued to all employees at the start of the program to encourage participation.
CPA Global reports that its NAVEX Global platform enables it to streamline the communication of its foundational ethics and corporate conduct policies as well as to make those policies more relevant across the organization. This has an impact on the speed of program completion and retention of content.
To the first point, the company reports a faster rate of completion than with any prior training efforts. Prior to its deployment of the NAVEX Global platform, the company would expect completion certifications from around 40% of its employees after the first four weeks of a campaign. After its first deployment of the NAVEX Global platform, it achieved a 95% completion rate in that same period of time.
The company also reports gains in internalization and application of learning. Following training, CPA Global saw an increase in questions raised by employees and requests related to the new gift policy. The company could not provide measured increases but reports anecdotally that it observed a significant increase in red flags reported. An increase in concerns raised and requests for approval represents crucial leading indicators of retention and use of learning, thus providing some directional evidence of potential for changed behavior. It also has an important, indirect impact on compliance performance. This is because the earlier an issue is raised, the less work and cost that is often required to address it, often by identifying exceptions or easy means of remediation. CPA Global indicates that it plans to begin measuring these factors and tracking correlations to training programs.
Table 1: Key Elements of CPA Global’s Training Program
- Online, global accessibility
- On-demand delivery
- Employee convenience
- Increased completion rates
- Scalable cost of delivery
- Short vignettes
- Escalating content based on in-content answers
- Company-relevant content and options on questions
- Increased engagement
- Increased internalization of best practices and “real world” context
- Identification of consequences
- Identification of company-relevant risks
“If I need resources and desire funding, my business case sells our program, talk about how our clients value our program. Not only are we avoiding the enforcement defense issues, our clients see our program as providing additional value. This draws from our program as well as investments we make in security and continuous monitoring of changes in third party risks, export controls, and economic sanctions to help manage risks to their IP strategies.”
-Mark Speck Head of Global Audit and Chief Compliance Officer CPA Global
Blue Hill Analysis: Investment Success
CPA Global’s primary compliance drivers relate to company reputation and customer trust. This is somewhat unique. Reputational drivers tend to be reported as secondary, as organizations often prioritize operational overhead and exposure to agency action as top motivators for compliance investments. For this reason, measuring of the success of CPA Global’s investments requires that primary emphasis be placed on the ultimate impact on customer satisfaction, retention, and revenue growth followed by impact on the efficiency of compliance operations.
Connections between compliance and top-line metrics such as revenue are often too remote to permit meaningful measurement. CPA Global has avoided trying to draw these correlations. Instead, the organization has focused on measuring training engagement and impact. These factors align to CPA Global’s top solution selection concerns and offer some indication of the program’s ultimate impact on its compliance drivers. To make the connection to customer satisfaction, it has also used client surveys to collect anecdotal evidence regarding the importance and perceptions of its compliance and ethics standards. As a result, the company is able to obtain some measurement of the connection between its compliance program and customer satisfaction. The company reports that it generally receives feedback that the high quality of its compliance program provides added value and differentiation. As a result, the company is able to draw indirect connections between its compliance investments and revenue retention and growth.
Table 2: Blue Hill Summary of CPA Global Success Factors
Speed of Delivery
- Online, on-demand access
- “Tone at the top”
- Engaging formats
- Rate of completion certification
- Time required to complete training
Impact & Retention
- Short materials
- “Tone at the top”
- Consequence identification
- Training impact and retention
- “Safe” whistleblower options
- Time required to address issues
- Size of compliance department
Business Function Efficiency
- Speed of delivery
- Training impact and retention
- Time required to complete training
- Time required for remediation
- Time required for litigation
- Training impact
- High ethics standards
- Continuous monitoring of related compliance issues
- Customer reports of compliance value
- Prospects with a compliance element as selection prerequisite
- Customer reports of perceptions of compliance program
In addition, the company is beginning to track the prospects and current clients that have requirements for data privacy protection, ethics, export controls, or anti-bribery compliance program descriptions. CPA Global is thus able to tie the impact of its compliance investments to its top driver related to customer support and protection.
While secondary drivers for CPA Global, Blue Hill also finds that the company’s deployment is likely to generate operational and other infrastructure savings.
Operational gains from compliance investments generally involve improved efficiency in compliance operations as well as business functions. CPA Global reported improved efficiency in compliance as a result of earlier identification of issues. Increased efficiency in compliance allows compliance departments to scale operations along with organizational growth and increases in compliance complexity without adding staff unnecessarily.
For business functions, early resolution of issues helps to reduce time that is consumed in investigation, remediation, and potentially litigation of a compliance matter. These dynamics reduce “non-productive” uses of business managers’ time and permit increased focus on value-producing activities. In addition, the company’s online, on-demand deployment offers potential cost savings related to the roll-out of training across a large, global organization.
CPA Global demonstrates how compliance investments relate to larger enterprise business performance, including top-line growth. By partnering with NAVEX Global, the company was able to increase the impact of training through on-demand, interactive videos while simultaneously reducing the costs of deploying training across enterprise functions. The company links its investment to faster completion of training and improved policy retention and application, which have had a demonstrable effect on customer perceptions of value. While not a focus of its investments and thus unmeasured, Blue Hill also expects that CPA Global has generated cost savings related to deployment costs, compliance department efficiency, business function efficiency, and reduced compliance risk.
Organizations seeking to model business cases from CPA Global’s experiences will find that the clearest quantifiable cases relate to compliance overhead. Drawing the connection to customer engagement often requires some expansion in how organizations typically view the value of compliance operations. Investigation of how customers view the organization’s compliance performance and its relative importance to them offers first steps to building a similar case.
About NAVEX Global, Inc.
NAVEX Global’s comprehensive suite of ethics and compliance software, content and services helps organizations protect their people, reputation and bottom line. Trusted by 95 of the FORTUNE 100 and more than 12,500 clients, our solutions are informed by the largest ethics and compliance community in the world.