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BELA Roundtable Series: TechnipFMC - Houston Texas

A BELA Roundtable Series Recap & Polling Results ReportPrepared for the BELA Community // May 13, 2020

Participating Organizations

• 3M

• Alcon

• Archer Daniels Midland

• Baker Hughes

• BDP International

• Black & Veatch Holding Company

• Cementos Progreso

• Constellations Brand

• Crocs

• Diebold Nixdorf

• DISH Network

• DTE Energy Co.

• Ericsson

• Fresnillo

• General Motors

• International Paper Company

• Nissan

• Penoles

• Sertecpet

• Texas A&M Agrilife

• TechnipFMC

• The J.M. Smucker

• Waste Management

• Westinghouse Electric

• Wood Group

Ethisphere Resources

Making the Case for Compliance in

Uncertain Times

Volume One: Remotely Managing a Global Program Effectively

Building an Ethical CultureTopic Lead: Technip FMCRecap:• Involvement of the employees and management team are a

key part of the success of the culture of integrity of an organization

• Integrity based culture is characterized not only by implementation of clear policies and procedures such as having a strong code of conduct based on the organization values, also tone from the top and tone from the middle

• Compliance professionals should manage the operational risks but also implement and manage the culture of integrity

• Authorities around the world are promoting the companies to access the effectiveness of the compliance programs including its culture aspects

• At TechnipFMC everything that they do is driven by the needs of the involving business, their values and the behavior expectation.

• TechnipFMC’s program is built on fundamental beliefs of integrity, safety, quality, sustainability and respect.

• TechnipFMC’s Core values and foundational beliefs and take 5 initiative.

• TechnipFMC’s take 5 initiative: all meetings that have more than 5 people, they do a take 5 initiative on their foundational beliefs

Best Practices:• Consider focusing on the effectiveness of your internal

controls and your culture of integrity

• Consider to develop your program not only on control mechanisms but also on the culture of ethics

• Consider having a values framework based on your core values, behaviors and foundational beliefs

• The Culture of the integrity must be embedded in company values and programs.

• Consider having proper control mechanisms with a risk based approach

• Consider having a culture of integrity based on consistency and transparent communications of messages of ethics & compliance

• Consider having a culture of integrity based on EEE (Education, Engagement and Empowerment of the Employees)

• Corporate Culture based on Integrity has the core of a strong and sustainable compliance program.

Suggested Resources§ The Resilience Factor: How Challenges Can Strengthen Ethical Culture – Esthisphere Webcast

§ Dive Into Culture Data| Ethisphere Magazine

§ Presentation on Building an Ethical Culture | Lincoln Financial Group

§ Manager Tool Kit | Allianz

§ Manager Tool Kit | SABIC

§ Ethics Liaison Program | Jones Lang LaSalle

Build an Ethical Culture

How can you effectively Measure your Ethical CultureTopic Lead: Waste Management

Recap:

• When we are measuring an ethical culture we are also measuring a compliance culture

• Strong values and commitments make a robust ethics and compliance program which impacts employees behaviors and create a strong culture of compliance and ethics

• Formally evaluate your program to start getting data

• One way to measure your program is by focusing on looking at the data you have, and what data can you create

• Doing an Ethical Culture Survey is way that you have to create data and analyzing by accessing your training statics, your hotline

• When looking at your data try to identify trends, action items, things you can do to improve your program

• Waste Management have been using Ethisphere’s Ethical Culture survey for the last two years. Initially focused only on supervisors and managers

Best Practices:

• Consider continuous evaluating your compliance program by formally evaluating it

• If you can’t measure your program you can’t improve it

• Consider doing “pulse surveys” to continuous improve your program

• Consider benchmarking your survey results

• Consider engaging an outside provider to evaluate your program and effectively measure your ethical culture

• Understand your business well and what you are trying to accomplish and who do you want to survey (by location, by country, by business unit, post-acquisition, by group of employees such as supervisors, managers)

• Consider making the survey anonymous and communicating the results to the employees.

• Consider conducting the survey annually to:

Ø Monitor the progressØ Check organizational changesØ Examine high-risk groups

Suggested Resources

§ Measuring Ethical Culture | Ethisphere Infographic

§ Ethisphere’s Ethical Culture Insights Report - Volume 1 focusing on Elements of Ethical Culture, Observing and Reporting Misconduct, and Perceptions of Senior Leaders

§ Ethisphere’s Ethical Culture Insights Report - Volume 2 focusing on The Role of the Manager in Influencing Ethical Culture

§ Ethisphere’s Ethical Culture Insights Report – Volume 3 focusing on The Case for Investing and Engage Effective Training and Communications

How can you effectively Measure your Ethical Culture

10

Incorporate Novel Training & Communication Practices to Bolster your Program Topic Lead: Technip FMCRecap:• TechnipFMC is using innovative ways to provide clear, concise

information to the business

• Designated Regional Compliance Counsel within the regions, integrating themselves into the business in order to built the necessary trust with the employees.

• Partner with their Communications, Learning and Development team to create ”we are listening podcast” done by Natalia Sheahdah, Technip’s CCO, discussing high level topics such as building an integrity culture and why it is so important

• TehcnipFMC uses an internal communication system called “yammer” where they drive compliance communications to different audiences, have the capability to message through Yammer the whole company or different sites

• Yammer campaigns during Covid-19 :

• “Keeping In Touch” sharing uplifting stories, uplifting messages, keeping everybody engaged in the business

• ”Showed us your co-workers” where employees are posting pictures of their families, their fur babies with hastags, that really went long way to help their employees during this turbulence time.

• Fit for purpose training: concise, direct, and applies to their day to day work being more impactful to their audience.

• Job Aids: one pagers that summarizes the training and employees can keep on their desk and if they have a question that they can simply desk reference, and also tells how to get in touch with the compliance department.

• Newsletters: regional newsletters that highlights compliance matters and risks, how you can contact the ethics hotline, trends they are seeing in investigations. Seasonal newsletters: discussing gifts and hospitality around the holidays. They track the of the download rates of newsletters.

• Microlearning's: short on line base trainings created in-house that can last from 5 min to 20 min

• Take 5 moment: Before every meeting and specially if there is 5 or more people in the meeting there is a take 5 moment that kicks off that meeting and is topic driven. Recent examples: HSE did one on the importance on washing your hands, importance of wearing a mask when you are going back to the office. Compliance take 5 are usually done with pictures.

• Launch Transparency & Integrity initiative: provide insights of the compliance program such as statistics on investigations, statistics of completion rates of trainings, trends and lessons learned from investigations

• Investigations Lessons Learned: high level summary of an investigation, stating what went well and what didn’t. what what was the outcome, optimizing the data so employees cannot figure out what region was it and what employees were involved.

Incorporate Novel Training & Communication Practices to Bolster your Program Topic Lead: Technip FMC

Best Practices:

• Consider be transparent to the business as much as you can, transparency is key to a compliance program success

• Consider ways to engage the employees, through videos, internal communications, leadership messages, game training and competition

• Consider launching global initiatives during a time that makes sense for the organization

• Consider using polling questions on training methodology and on your communication methodology

• Consider walk away from delivering long deck of slides presentations for training, instead create a short training that directly relates to the audience you are presenting to

• Consider implementing ”newsletters” that goes out monthly or quarterly

• Consider communicating to your employees investigations results in a “high level summary” shows that you are listening to theirconcerns and that you take their concerns seriously. Also shows that investigations do happen and you share the outcome

Suggested Resources

§ Lear Corporation’s Safe Work Playbook, an interactive guide for COVID-19 Pandemic Preparedness and Response

§ JLL’s Slides for Ethics Liaisons Communications created for their Ethics Liaisons to use in meetings

§ Oshkosh’s Communications Aligned with Values, documents include: Messages from CEO and CCO, Poster on Oshkosh Values, Example of Weekly Newsletter with updates on COVID-19

§ Bayer’s Compliance Message for Leadership, consistent message from executive and senior leaders on different topics

§ American Airlines’ Infographic on Hotline Reporting Numbers