Benchmarking Your Policy Management Program

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www.navexglobal.com © 2015 NAVEX Global, Inc. All Rights Reserved.


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Benchmarking Your Policy Management Program

May 21, 2015

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P R E S E N T E D B Y

Senior Vice President, Advisory Services

NAVEX Global

Andrew Foose

Senior Vice President, Advisory Services

NAVEX Global

Randy Stephens




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• The Role of Policy Management in E&C Programs

• Hidden Costs of Policy Management

• Key Findings

State of Policy Management Today

Processes & Tools for Policy Management

Addressing Legal & Regulatory Policy-Based Risks

• Key Takeaways & Recommendations

• Q&A + Additional Resources

Agenda




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• What are E&C professionals doing to manage policies today?

• Are some approaches more effective than others?

• Is there a better way?

The #1 differentiator in respondents’ effectiveness rating was policy management software.

E&C pros using automated software rank their effectiveness 2-3 times higher in key areas than those without.

Learning Objectives of Our Policy Management Research




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Policy Management Benchmark Report Statistical Snapshot

• First and largest report of its kind by an independent resource company

• Collected anonymously

• 879 respondents across 18 industries

• Respondents include:

C-Suite (10%)

Senior Managers/VPs (44%)

Managers (29%)

Non-Managers/Other (17%)

• Respondents represent small, medium and large companies (roughly 1/3 of each)




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Policy Lifecycle Process Should be Efficient, Repeatable, Auditable and Defensible

PUBLISH / ARCHIVE CREATE

Draft Reviewers Approval Distribute Certification

Queue for Later Release

Publish

Document owner

Archive

Policy draft Subject Matter Experts Approver

Users




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Hidden Costs of Policy Management

Policy Management

• Document creation & editing

• Reviews & approvals

• Audit & accreditations

• Data collection, analysis, and reporting

Increased Oversight/ Risk Reductions

• Increased awareness

• Reduced regulatory actions

• Reduced litigation & settlement costs

Current Process Costs

• Searching & retrieval time

• IT cost reductions

Policy Training & Communication

• Management time delivering trainings

• Policy sign-off attestation




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Attendee Poll:




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Key Findings




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K E Y F I N D I N G S

STATE OF POLICY MANAGEMENT TODAY




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Attendee Poll:




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Top Policy Management Challenge: Training

Source: NAVEX Global's 2015 Ethics and Compliance Policy Benchmark Report

http://www.navexglobal.com/file-download?file=uploads/NAVEXGlobal_2015_Policy_Management_Benchmark_Report051815.pdf







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Many Document Types Being Managed









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More Than 51% of Respondents Manage 100 or More Documents









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• Are you managing too many policies—or not enough?

• Is your policy management program truly protecting your organization?

• What is your organization’s risk-ranked liability related to policies?

• A risk assessment can help you answer these questions. Your policies should align with your organization's risks—and your policy management program should be structured to appropriately address each risk.

Policy Management Approach Should be Based on a Sound Risk Assessment




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• Budget owners for policy management program varied:

Policy Management is Part of Our Company-Wide Budget (20%)

Ethics & Compliance (20%)

Human Resources/Employee Relations (19%)

Legal (13%)

Quality Control (9%)

Risk (9%)

Information Technology (8%)

Safety (6%)

Other (11%)

Policy Management Budget Owners Vary









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Policy Management Budget Owners Vary









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• If your policy management budget has no specific owner (it’s part of your company-wide budget) consider advocating for an owner.

• This will allow the owner to calculate program ROI, and advocate with leadership to ensure the program has the resources it needs to succeed.

Defined Budget Ownership is Imperative









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1/4 of Respondents Don’t Know the Size of Their Policy Management Budget









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FTEs Dedicated to Policy Management Vary









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• FSGO states that an effective compliance program should have “adequate resources”—but those guidelines are not prescriptive.

• It’s up to each company to determine if they meet the standard. That needs to include a reasonable budget for the key program element of policy management. Key questions to ask should include:

Do we have the right range of policies to address our risks?

If changes are needed in our policies, what level of effort will be required to make those changes in a timely manner?

Do those assigned the task have enough dedicated time to manage the policy lifecycle in a manner that is efficient, repeatable, auditable and defensible?

FSGO: Resources Must be “Adequate”









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59% of Respondents are Not Creating Language- or Region-Specific Versions of Policies









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Best-in-breed organizations provide versions of policies that reflect the unique requirements of recipients, local regulations or other facility-specific needs.

For all policies, organizations should distribute translated versions to multilingual employees. Best practices are to:

• Translate policies into the main language(s) of each country in which the organization operates; and

• Localize policies so that they are respectful of countries and local cultures while maintaining the integrity of the core policy elements.

Policies Should be Translated & Localized









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PROCESSES & TOOLS FOR POLICY MANAGEMENT




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Attendee Poll:




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Policy Management Programs are Maturing









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25% of Respondents Have Policy Management Software; 25% Still Using Spreadsheets









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• If the watchwords for best practice policy management are efficient, repeatable, auditable and defensible, automated software is the answer.

• Piecemeal or patchwork approaches cannot achieve all of the key goals.

Centralized, Automated Approach Creates Peak Effectiveness









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Our Ethics & Compliance Ecosystem

Employee Awareness

Standard & Ad-Hoc Reporting

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www.navexglobal.com

Our Ethics & Compliance Ecosystem

Employee Awareness

Standard & Ad-Hoc Reporting

Exp

and

ed

In

take

INTEGRATED COMPLIANCE DATA

AD

VIS

OR

Y S

ERV

ICES

NAVEX GLOBAL GATEWAY

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In-Person Training Top Choice for Ensuring Policy Comprehension









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Risk rank stakeholders and use a variety of methods to make sure that those with the highest-risks have clear comprehension on related policies.

Integrate policies into core E&C elements to make sure they are working as hard as they should.

Integrate policies in…

• Training: Provide links to policies within online training

• Case Management: Make it easy for investigators to check policies related to an open E&C case

• Hotline/Web Intake Reporting Processes: Make it easy for potential reporters to check a policy related to an issue they are reporting

Ensure Comprehension Using a Variety of Methods Related to Risks & Roles









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58% of Respondents Do Not Measure Policy Management Program Effectiveness









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39% Do Not Review Policies Regularly









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• From legal and quality standpoints, outdated policies and procedures are a liability.

• They can also undermine employee confidence that policies are to be taken seriously.

• A schedule for reviewing and updating policies should be established by policy stakeholders, then followed and audited.

• To determine the right schedule, consider your organization's risk factors and create a cohesive plan.

Outdated Policies are a Legal Liability









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Comparing Effectiveness of Automated vs. Non-Automated Policy Management Programs

Respondent Rated

Program as Very Good

or Excellent in…

Respondents

Without Policy

Management

Software

Respondents With

Policy Management

Software

Conclusion

Access to Policies 28% 56%

Respondents

with software

more than twice

as effective.

Compliance

with Policies 15% 42%

Defensibility

of Policies 10% 29%

Workflow Between

Writers & Approvers 10% 30%

Respondents with

software are

nearly

three times

as effective.









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ADDRESSING LEGAL & REGULATORY POLICY-BASED RISKS




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Attendee Poll:




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33% of Respondents Faced Legal or Regulatory Action Where a Policy Came Under Review









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38% Keep Records on Some Policies, But Not All









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71% Require Formal Attestation on One or More Policies









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55% of Respondents Don’t Require Annual Re-Acknowledgement of Policies









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• The lack of an audit trail for policies opens the door to legal liability.

• It also signals to auditors and employees that the organization does not take their commitment to policies as seriously as they should be.

• Organizations must maintain detailed records at every stage of policy development for each policy.

• Whether these activities are tracked manually in spreadsheets or in a centralized, automated policy management system, the best practice is to maintain a centralized, standardized and controlled environment to mitigate legal risk.

Detailed Records are the Best Defense




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KEY TAKEAWAYS & RECOMMENDATIONS




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• Define a comprehensive, ongoing, risk-based approach

• Understand your universe of risks

• Assess your vulnerabilities

• Track program effectiveness

• Establish training on policies that address key risk areas

• Align resources with policy management efforts

• Be ready to handle legal action

• Implement automated software

Key Takeaways




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What Policy Management Programs Today Need to Thrive • Goals: Aiming to ensure that policy management programs are efficient (rather

than manual), repeatable (rather than one-off), auditable (rather than scattershot), and defensible (rather than hit-or-miss) is an important milestone E&C pros should aim to reach.

• Dedicated Budgets: Carving out a dedicated policy management budget (even if that is just getting clarity on existing expenditures) is another key milestone organizations should work toward.

• Designated Ownership: Policy management programs need a clear, designated owner to oversee company-wide policy management effectiveness and advocate for appropriate program resources.

• Performance Effectiveness Measurement: Organizations must measure policy management program costs and effectiveness to fully understand the scope of policy management impact on overall E&C program effectiveness.




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Strong Policy Management Practices Strengthen E&C Programs

• Policies are the backbone of a strong E&C program.

• Policies themselves—as well as how they are handled throughout their lifecycle—must meet the gold standard of being efficient, repeatable, auditable and defensible to truly protect an organization from legal, regulatory and behavioral risk.




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Additional Policy Management Resources

• Policy Management Thought Leadership: www.navexglobal.com/Resources

eBook: The Definitive Guide to Policy Management

On-Demand Webinar Series: Policy Management Bootcamp: a Webinar Series on the Definitive Guide to Policy Management

Article from NAVEX Global’s Ethics & Compliance Matters TM Blog: How Do I Know If My Policy Management System Is Working?

• Policy Management Software Solutions: www.navexglobal.com/PolicyTech

Learn more about our best-in-class policy management software solution, PolicyTech.

• Expert Consulting Solutions: www.navexglobal.com/AdvisoryServices

Learn more about how the experts on our Advisory Services team can help you identify and address program gaps with framework reviews, program assessments, code of conduct reviews and more—or request a consultation today.

http://www.navexglobal.com/Resources

http://www.navexglobal.com/resources/referenceguide/Definitive-Guide-Policy-Mgmt

http://www.navexglobal.com/resources/webinars/Policy-Management-Bootcamp_Series

http://www.navexglobal.com/resources/webinars/Policy-Management-Bootcamp_Series

http://blog.navexglobal.com/2015/02/09/how-do-i-know-if-my-policy-management-system-working

http://blog.navexglobal.com/2015/02/09/how-do-i-know-if-my-policy-management-system-working

http://www.navexglobal.com/PolicyTech

http://www.navexglobal.com/PolicyTech

http://www.navexglobal.com/AdvisoryServices

http://www.navexglobal.com/resources/get-demo-Advisory-Services




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Click the Image to Read More on Our Blog

http://blog.navexglobal.com/




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Thank You for Your Participation!

Andrew Foose Vice President, Advisory Services [email protected]

Randy Stephens Vice President, Advisory Services [email protected]

mailto:[email protected]

mailto:[email protected]

Date post:	29-Jul-2015
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Benchmarking Your Policy Management Program

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