adding engagement to your code of conduct · 2014. 10. 28. · adding engagement to your code of...
TRANSCRIPT
Adding Engagement to Your Code of Conduct
November 7, 2014
Tara Mancinelli & Lynn Hamilton – Lockheed MartinElaine Ott – NYSE Governance Services
©2014 Lockheed Martin Corporation
Global Partnerships for the 21st CenturyGlobal Partnerships for the 21st CenturyGlobal Partnerships for the 21st Century
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WellingtonSao Paulo
› 200+ year history of governance leadership
› 16+ years in Compliance & Ethics space
› 4,600 Codes/policies reviewed
› 225+ Codes of Conduct written
› Thought leadership/research
About NYSE Governance Services
Code Update Project Goals• Reflect Changes in Law, Regulation and Policy
• Redesign for Engagement– Same Key Messages Less Words
– Link to Supplementary Resources
• Explain “Why”– Less Legalese
– Code is a Resource, not Repeat of Policy
• eBook Delivery for Majority– PDF and Hard Copy Versions Available
Current, Digital, and Interactive
Major Change Takes Time
Getting Buy In from Stakeholders Early OnGetting Buy In from Stakeholders Early OnGetting Buy In from Stakeholders Early On
OLDP Benchmarking
February 2013
Team Kickoff
July 2013
Final Product
June 2014
The Team• Ethics Core team
• Graphics/Technical team
• Employee Focus groups
• Security Engineering
• Human Factors Engineering
• Command Media (policies)
• Human Resources
• Legal
• EEO
• Contracts
• Privacy
• Learning & Development
• Information Security
• Safety
• International Ethics
• Security
• Sustainability
• Washington Operations
• Labor Relations
• Several employees who helped with proofing
Code Creation Roadmap
Project Initiation1 Week – 6 Months
Code Text Authoring4 Months – 1 Year (+)
› Establish Code communication style goals
› Create Code outline› Draft Code text› Host review sessions
throughout› Host focus groups (if
desired)
Code Design & LayoutAdditional 6 Weeks – 4 Months following text completion
› Define Creative vision› Establish Code presentation
composition› Pair sample with Code draft
text for review team› Layout text following Code
completion› Launch
› Assemble Code team› Host project launch meeting› Define end-user needs and
experience goals› Perform data analysis Current code review Peer benchmarking Policy content and gap
evaluation
Code Team Makeup
Lean Approach
› Compliance Project oversight
Primary drafter or primary reviewer
› Legal Subject matter expert review
› Human Resources Subject matter expert review
Communications and launch assistance
› Communications Content review for readability, tone and organizational “voice”
Design and Layout lead or reviewer
Code Team Makeup
Robust Team Approach
› Project Leadership Compliance Lead
Project Manager
› Subject Matter Experts Compliance (Domestic and
International)
Corporate Social/Sustainability Responsibility
Finance
Human Resources
Information Security
Internal Audit
Labor Relations
Legal
- Risk area specific expertise
Procurement
Risk Management
Safety
Technology
› Additional Content Review Communications/Marketing
Department/Division Managers
Employee Focus Groups
Third Party Assistance (Consultative and/or Outside Counsel)
Key Content Changes
• Significant New Content– Sustainability
– Security
– Retaliation: Definition and New Whistleblower Protection Law
– Drug Free Workplace: Marijuana
– Labor: Right of Free Association, Wage/Hour Laws and Benefits
– Prohibition on Trafficking in Persons
• Added “Interactive” Supplemental Content– Policies can be updated in both internal and external eBook
– Supplemental material can be kept fresh/current
Code Review and Updating
Launch New Code
One Year Later
Review content for policy, procedure and regulatory
updates
Update as needed (minor)
Two Years Later
Review updated best practices to determine if edit or rewrite is
needed. If only an edit is needed, update content as appropriate,
include new comprehension aids and design.
Three Years Later
Launch refreshed Code with updated training and related communication
materials
Code of Conduct eBookwww.lockheedmartin.com/us/who-we-are/ethics/code-of-ethics.html
Major Milestones
Milestone Date
Kickoff 7/16/2013
Face to Face Meeting 11/12-13/2013
Coding 11/18/2013-2/28/2014
Test Readiness Review 3/26/2014
Test/Corrections 4/4-6/23/2014
Operational Readiness Review (ORR) 6/24/2014
Ethics Committee Approval 6/25/2014
Course Code in Catalog 6/25/2014
Board of Directors Approves Resolution 6/26/2014
Production Deployment – Internal/External 6/26/2014
Initial LM News Communications 6/27/2014
Course code shows in Learning Plan 6/30/2014
UAT and Performance Test Results
UAT
• 15 functional test cases
• Cumulative Discrepancies:– 333 Functional Discrepancy Reports
– 8 high, 301 medium, 11 low
– 190 Technical Errors
– 143 Text/Language corrections
Performance
• Load testing was performed with concurrent user base of 1500 users
Devices/Browsers
• Android phone
• Chrome
• Firefox
• IE10
• IE8
• iPad Company
• iPad mini GOOD
• iPad mini Personal
• iPad Personal
• Safari Personal
• Samsung tablet
• iPad through LM Passage
• iPod Touch
• Macbook Safari
• iPhone Company Safari
• iPhone Personal
Mobile View
• Testing Results changed roll-out plan
• Mobile view worked, but…– Not ideal for certification process mainly due to font size
– Works to certify through “deep link” to MyLearning but clunky
• Intended as a reference tool after certification
NYSE GS – Key Issues to Consider
› Which parties need to approve the updated Code (including direction, content and design?) Individual Stakeholder(s)
Compliance and Ethics Committee
Works Councils
Board of Directors (or BOD committee)
› Does the content in the updated Code text align with published policies and procedures?
› If minor changes are needed, do you have authority to update as needed without BOD approval? Policy name updates
Contact information updates
› How are stakeholders going to utilize the Code and related documents? Offline employees
Translations
Employee populations that may benefit from a “pocket guide”
Internal or External?
Internal
› Drafting internally› Lead and manage reviews› Lead and negotiate discussions on best
practices and content decisions› Streamline content written by numerous
SMEs to harmonize language and flow› Utilize internal resources for design and
layout› Create communication materials and
manage print production
External
› Drafting externally› Lead and manage reviews (internal)› Third party can assist internal
discussions on best practices and content decisions
› Leverage external expertise to streamline content for consistent voice and flow
› External design expert creating design and layout
› Communication materials and launch plan created externally for internal action
Translations• Arabic
• Dutch
• Chinese (Simplified)
• Chinese (Traditional)
• French
• German
• Hebrew
• Spanish
• Indonesian
• Japanese
• Korean
• Malay
• Portuguese
• Romanian
• Turkish
NYSE GS – Translations Benchmarking
Communications
• LM News announcement – 6/27
• Leaderlink – 7/8
• HRlink – 7/9
• ePostcard – 7/15-17
• Leader Toolkit – 7/29
• Follow-up ePostcard – 9/7
Rolling Out the New Code
Follow-on Items
Action Item #
Description ECD
1 Website metrics Monthly
2Create web clip for mobile devices
7/31
3 Survey Plan 7/11
4 Gifts Decision Tree (TBD) TBD
5 Print versions expected to be mailed 7/14
6 Post audio version 7/10
7 Post translated versions 7/30
8 Update policy links and add award info 10/31
9 Update template to include feedback button 10/31
Employee Feedback
“Well structured with each success-oriented objective and "Why we do it" discussion.”
“…I felt the material was intended for a professional "adult" audience.
“Very refreshing.”