Upon successful completion of this program, participants will be able to:

• Differentiate between a compliance culture and a true ethical, values-based culture.
• Understand the critical role of "Tone at the Top" in shaping employee behavior.
• Design, implement, and maintain a protected, anonymous whistleblowing program.
• Develop and deliver effective ethics training that focuses on dilemmas, not just rules.
• Master the principles of conducting fair, prompt, and confidential internal investigations.
• Establish clear non-retaliation policies and protective measures for whistleblowers.
• Identify and address the ethical "blind spots" and biases in organizational decision-making.
• Measure the health of the ethical culture using employee surveys and cultural metrics.

• Ethics and Compliance Officers
• HR Directors and Employee Relations Managers
• Senior Executives and Board Members
• Internal Auditors and Investigators
• Managers responsible for direct team oversight
• Legal Counsel focused on labor and regulatory risk
• Risk Management and Governance Professionals

• **Scenarios:** An employee reports a conflict of interest involving a senior executive; participants must outline the investigation protocol and ensure non-retaliation.
• **Case Studies:** Analyzing the post-scandal recovery of a company and its steps to rebuild public trust by fostering a new ethical culture.
• **Group Activities:** Collaboratively designing an interactive ethics training module that addresses a common workplace dilemma (e.g., gifts and entertainment).
• **Individual Exercises:** Drafting a one-page "Tone at the Top" memo from the CEO emphasizing the importance of non-retaliation.
• **Mini-Case Studies:** Rapid evaluation of an internal reporting policy to identify weaknesses in anonymity and confidentiality guarantees.
• **Syndicate Discussions:** Debating the extent to which employee incentive plans should be linked to ethical behavior metrics.
• **Survey Design:** Developing five key questions for an employee ethics and culture survey.

Unit 1: The Foundation of Ethical Culture

• Defining organizational culture and its relationship to compliance and ethics.
• The importance of moving from a rule-based compliance program to a values-based culture.
• Understanding the psychology of ethical decision-making and cognitive biases.
• The business case for ethics: financial returns and reputational protection.
• Analyzing the impact of incentive structures on ethical behavior.
• The link between poor ethical culture and major corporate scandals.

Unit 2: Leadership and Tone at the Top

• Defining the ethical leadership responsibilities of the Board and Senior Management.
• Techniques for modeling and reinforcing ethical behavior daily (Tone in the Middle).
• Integrating ethical conduct into performance appraisals and promotion criteria.
• Developing a clear, accessible Code of Conduct that reflects organizational values.
• Communicating ethical expectations consistently across all geographies and functions.

Unit 3: Internal Reporting and Whistleblowing

• The role of internal reporting (hotlines, ombudsman, managers) in risk detection.
• Legal and regulatory requirements for whistleblowing protection (e.g., EU Whistleblowing Directive).
• Designing a confidential and anonymous reporting mechanism and vendor selection.
• Developing a robust non-retaliation policy and communicating it effectively.
• Analyzing and addressing common barriers to speaking up in an organization.

Unit 4: Investigations and Remediation

• Mastering the principles of internal investigations: impartiality, confidentiality, and promptness.
• Developing investigation protocols for ethics and compliance violations.
• Ensuring due process and fairness for both the complainant and the subject.
• Techniques for conducting effective, legally sound interviews.
• Determining appropriate, consistent disciplinary and remedial actions.

Unit 5: Training, Communication, and Measurement

• Developing engaging, scenario-based ethics training that focuses on dilemma resolution.
• Utilizing internal communication campaigns to reinforce key ethical messages.
• Measuring the health of the ethical culture through employee perception surveys.
• Analyzing hotline data and investigation outcomes as leading indicators of risk.
• Strategies for continuous improvement of the ethics and compliance program.