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Compliance


Code of Conduct/Compliance Courses


Code of Conduct - The Roots of Compliance

This course incorporates your organization’s code of conduct policy into a high-energy interactive experience in which participants will be made aware of relevant legal responsibilities, ethical expectations and values. Course module content may include: accuracy of records; conflicts of interest; acceptance and giving of gifts; inbound/outbound immigration processes; outside employment/ownership in other businesses; nepotism issues; record retention; confidentiality and proprietary information; data security and privacy; technological resources; intellectual property issues; financial reporting; antitrust; international trade and export controls; US government regulations/contracts/investigations; environmental issues and impacts; and political contributions/lobbying/gifts. This course can also be easily customized to address federal government regulations requiring business ethics and compliance awareness programs for federal contractors.


Reading the Signs of Compliance

Department of Justice, SEC, EEOC and other governmental enforcement actions have increased, putting employers and individuals at risk of significant penalties, fines and/or imprisonment. As such, today it is critical that your leadership and workforce protect itself from unnecessary litigation and liability.

All too often, those of authority find that they miss critical opportunities to support an organization’s ethical standards or escalate issues before they blossom into liabilities or reputational hazards. Using SSAW’s hallmark imprinting mantras, visuals and scripts, Reading the Signs of Compliance connects the dots between all areas of compliance for your managers and supervisors (and, as necessary, employees), and helps develop practical, consistent compliance strategies and organization-wide responses. This interactive session illustrates how your code/policies can and should be applied to serve as roadmap to effective and compliant decision-making and how its rules impact the daily lives of your organization’s leaders and employees.

True behavioral/management buy-in around best practice strategies comes from high-impact and interactive consensus building. It comes from an approach that has been vetted by federal agencies in numerous nationwide consent decrees. It comes from SSAW’s uniquely dynamic design and delivery approach.

Customized at no cost, Reading the Signs of Compliance allows you to select those areas of compliance/code of conduct provisions that matter most. Our design team links your selected topics around our proprietary thematic elements, which enable participants to adopt a big picture and best practice approach. Simple, practical issue spotting and relevant examples enable your managers and supervisors to come to agreement on best practices that will enable them to apply skills in the workplace, in transaction/sales situations or in off-premises interactions that may affect the workplace.

Linked Modules Can Include:

  • Latest Liability Trends
  • Anti-Trust
  • Conflicts of Interest
  • Gifts
  • Foreign Corrupt Practices/ U.K Bribery, etc
  • Federal Acquisition Regulations
  • False Claims Act
  • Insider Trading
  • Employment / Consistency in Management
  • HIPAA
  • Data Privacy
  • Whistleblowing / Retaliation
  • Use of Electronic Communications
  • Social Media
  • Reporting and Escalation
  • For appropriate levels, key regulations and court decisions are reviewed, as well as latest key trends and liabilities. Exposure risks related to DOJ, SEC, EEOC and private litigants/shareholder charges are all explored and practical prevention strategies imprinted.


    E-Mail and Internet: Misuse, Misconduct and Mistakes

    This interactive and high-energy training comprehensively covers the risks and best practices associated with e-mail/electronic systems use, as well as emphasizing the notion of a “business system” and the related expectations and responsibilities of all employees and managers in utilizing your company’s electronic communications systems. Throughout this training, participants will refer to your company’s electronic communications policy, as well as any related harassment policies and code of conduct sections.

    Participants achieve a fuller understanding of their responsibilities and the risks associated with accessing inappropriate sites via the internet or sending/forwarding emails referencing gender, race, religion, disability or other protected categories. Participants also will learn the three greatest “Danger Zones” related to e-mails/blogs and social networking today, including the enormous risks associated with defamation. The course addresses related topics such as: confidentiality; proprietary information; unfair competition; e-mail and record retention; data security; intellectual property and financial reporting. Latest trend National Labor Relations Act (NLRA) ramifications can also be stressed. Managers and employees successfully achieve the critical skills to “take a moment” and use proper business judgment and appropriate email etiquette before drafting, forwarding or sending e-mails.


    Whistleblower Training: Including SOX for Private Employers

    Enhancing Our Responses – Reducing Our Risks

    The Supreme Court has created an entirely new set of liabilities for private employers. For the first time, in Spring 2014 high court ruling, private companies that contract with or provide services to public companies can be sued under Sarbanes-Oxley whistleblower provisions if they retaliate against their own employees for reporting fraud at the public company.

    The Sarbanes-Oxley Act of 2002 already stated that no public company may retaliate against its own employees who raise complaints ("blow the whistle") related to misconduct or fraud. Federal legislation over the last decade steadily increased the risks of federal lawsuits based on employee complaints of retaliation for reporting unlawful or unethical conduct. And recent cases give employees an incentive to run directly to governmental agencies, especially if a complaint is mishandled. As such, private employers who serve public companies must act proactively and vigilantly to ensure that effective, broad-based and credible policies and complaint-response training are in place, even when the complaint is not about their own operations/actions. Managers (as well as key employees) must now be fully trained and knowledgable regarding what to say - as well as how to say it - in addition to how best to safely escalate and follow-up when someone complains about their customer/client.

    A Solution to this Emerging SOX Paradox for private employers:

    Seyfarth Shaw at Work (SSAW) offers high-impact training that ensures your policies will work on the ground and that will imprint the following critical, linked skills:

  • Issue and complaint spotting - what do we listen for?
  • Understanding that complaints about the companies we support and service matter, no matter how seemingly trivial or irrelevant to our own operations;
  • Responding in ways that convey empathy and support - but are not inappropriate admissions;
  • Handling objections and questions (with simple, safe and tailored scripts);
  • Utilizing escalation methods that create a compliant record of good-faith.
  • Reducing and imprinting skills and scripts so they are memorable and user-friendly

  • Working Within the Code

    This course provides essential training to non-supervisory employees in every day language about your organization’s code of conduct. Employees are given a basic understanding of how to identify workplace issues and how to respond to and report risky or prohibited conduct. In the harassment and EEO contexts, the course also can serve as a refresher, covering all protected categories including race, color, religion, national origin, age, gender, disability, sexual orientation, etc. For organizations with a global presence, Working Within the Code can be customized to address relevant international laws and country-specific policies.


    Confidentiality and the Code (including HIPAA and PII Focus)

    While the myriad of issues related to confidentiality are addressed in our Roots of Compliance and email courses, organizations with sensitive and proprietary materials often require a more in-depth analysis of confidentiality concerns. From Non-Disclosure Agreements to Non-Compete Clauses to HIPAA and PII Policies to general Confidentiality Agreements, this course utilizes your organization’s pertinent policies to emphasize the importance of keeping critical information safe, as well as educating employees as to what information should be protected. The course highlights how certain electronic communications including e-mails, may conflict with an organization’s confidentiality and privacy rules and what type of information can properly be discussed with third parties, including, customers, vendors, government officials and others.

    From a HIPAA perspective, we can cover:

  • What is PHI/Who is Covered
  • Individual Rights and Compliance/Enforcement
  • The Business Associate Exception
  • Minimum Necessary Standard
  • How do we prevent and handle breaches
  • etc.
  • And integrate key messages from the company's HIPAA/HITECH policies and any manuals.

    From a PII perspective, we can cover:

  • What constitutes PII? In what form might it exist? (hard copy, virtual, portable storage devices, off-site locations/access, etc.)
  • Whose PII are we concerned about? (employees, applicants, independent contractors, vendors, clients/customers, etc.)
  • What are our requirements for the security and protection of PII? (What rules apply to PII access, retention and destruction?)
  • When can we transmit PII to a vendor/others?
  • How do we prevent and handle breaches?
  • Etc.
  • What are our requirements for the security and protection of PII? (What rules apply to PII access, retention and destruction?)
  • When can we transmit PII to a vendor/others?
  • How do we prevent and handle breaches?
  • etc.

  • Health Care Fraud, Conflict of Interest and Abuse

    This interactive course focuses on policies and both federal and state laws related to health care fraud, conflict of interest and abuse claims. Tailored to your organization’s own specific issues, this course covers such topics as coding; billing; gifts; outside employment; reimbursement; financial reporting; and political contributions.

    Teaching tools including role-plays, hypotheticals and other interactive techniques stress real life examples. Versions of this course have covered: HIPAA, Medicare/Medicaid billing, working with HMO’s, false cost reports and activities/interactions of physician liaisons.


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