Ethics + Compliance Services

Executive and Board Training

JTI designs and delivers appropriately-tailored programs for executives and board members so they understand the extent of their responsibilities for E&C risk oversight. Mindful of their demanding schedules, JTI offers board members training sessions that “speak their language” and accommodate their time constraints. We share best practices of similar companies and boards and discuss current, high-profile cases in a way that is relevant to board members’ responsibilities as organizational stewards. Our presentations are creative, thought-provoking, and conducive to spirited dialogue.
Management Engagement

Direct managers have the most immediate and powerful impact on an employee’s perceptions about the workplace. E&C programs typically teach managers about the policies they are expected to uphold, but for ethics and compliance to truly become part of the fabric of the culture of the workplace, managers need to go beyond a “tick-the-box” mentality and be truly engaged. Managers must foster a culture in which employees feel free to voice concerns without fear of reprisal. They also should recognize employees who go beyond the norm to support a culture of integrity. JTI helps managers improve their skills at listening and responding appropriately when employees raise concerns, including knowing when and how to refer issues to other functional specialists. We coach managers on how to embed an “integrity mindset” into their day-to-day activities. By helping our clients inform and inspire managers, we help them improve the effectiveness of their E&C program.
Ethics and Compliance Program Assessment

The decision to conduct an independent E&C program assessment may arise out of a change in leadership, a request from the board, an interest in a particular issue, or a desire to demonstrate commitment to continually evaluate the program’s effectiveness relative to industry best practices. It could also come at the request of a regulator or investigator. Regardless of its origin, a program assessment helps reduce E&C risk for the organization. JTI can conduct an independent evaluation of an entire E&C program or focus on certain elements or sites/facilities. Our process typically includes in-person interviews, focus groups, surveys, and key document reviews. In addition to an in-person debriefing, we provide a written assessment against objective standards and best practices in which we identify and prioritize strengths and weaknesses. We present you with a plan to mitigate risks through remediation or improvement while also building upon strengths.
Ethics and Compliance Team Development

JTI helps our clients optimize the value and commitment of their teams of E&C Representatives. With our “Skill and Will” E&C Team Assessment, we gather information on elements such as their skills and confidence vis-à-vis their E&C responsibilities, how their performance is measured, and their views about the quality of the resources and management support they receive. Our “Skill and Will” assessment report highlights their strengths and recommends action items to enhance their effectiveness as strategic advisors. Whether the E&C Team is brand-new or mature, JTI also offers skill-building workshops and coaching to help team members excel in their E&C roles. JTI also supports individuals who are newly-appointed to an E&C role by developing a unique ”Get Started” plan for the first few months on the job, so they learn the relevant information sequenced by priority in order to build their capability and confidence in their new role.
Third-Party Risk Management

A recent survey found that 90% of FCPA (Foreign Corrupt Practices Act) prosecutions involved third parties. JTI delivers policies, guidelines, communication tools, and comprehensive yet practical training programs for clients interested in mitigating third-party risks proliferating around the world. We have trained in Asia, Africa, Latin America, Europe (East and West), and the US; we understand how to tailor materials and delivery to be understood and impactful in various national and business cultures. We don’t provide legal tomes and analyses that only lawyers would understand. Our training materials – and our in-person training – ensure that what is conveyed is meaningful and actionable by managers and employees who interact with third parties.
Ethics and Compliance Communications

JTI professionals work with our clients to develop and implement E&C communications plans that meet their company’s specific needs. We create targeted, “one-off” communications such as CEO or Chief Ethics and Compliance Officer newsletters, blogs, and memos to address specific E&C issues. We can also support clients on an ongoing basis by developing an annual editorial calendar that maps out key themes and supporting messages for communication during the course of the year. JTI can then produce all relevant communications and training materials. We match the right messengers with the best messages for the targeted audience using the most effective channels.
Employee Training in Ethics and Compliance

JTI creates training in a number of Ethics and Compliance topics. We can deliver workshops ourselves, or prepare training in a “Toolkit” form for clients to use internally. JTI Training Toolkits typically contain a Training Presentation, a Trainer’s Guide, a Frequently-Asked-Questions handout, “What-If” Scenarios offering guidance for situations employees are likely to encounter, and draft communications to executives, managers, and employees about the training. Some of the topics in which we have experience developing and delivering training to all levels of employees include:

  • Anti-Corruption / Anti-Bribery
  • Antitrust
  • Conflicts of Interest
  • Discrimination & Harassment Prevention
  • Gifts & Hospitality
  • Retaliation Prevention
  • Speak Up
  • Social Media
  • Third-Party / Supplier Compliance

Code of Conduct

A company’s Code of Conduct serves as the foundation of its Ethics and Compliance program. It should be clear and engaging. The Code is often an employee’s first exposure to the company’s values and expectations for business conduct. It serves as a critical tool for employees and managers alike, providing guidance in the resolution of ethical dilemmas and compliance-related questions. It also communicates the company’s commitment to E&C to regulatory agencies, stockholders, customers, suppliers, and other external stakeholders. Codes of Conduct should be updated regularly to keep pace with the changes that are occurring within the company, in the global business markets, and in the ever-evolving regulatory landscape. Whether creating an inaugural Code of Conduct or revising an existing Code, JTI helps clients create a valuable resource in a clear, accessible, and understandable format that provides needed guidance while emphasizing company values and a culture of integrity.
Ethics and Compliance Policies

While the Code of Conduct serves as the pivotal document for the Ethics & Compliance program, every company needs policies to address specific E&C issues in greater detail. Like the Code of Conduct, a policy must be clear and well-communicated in order to provide effective guidance to those whose actions come within its scope. JTI professionals are experienced at helping clients develop policies and procedures on subjects such as:

  • Anti-Trust and Fair Competition
  • Concern-Handling Procedures
  • Conflicts of Interest
  • Anti-Bribery and Anti-Corruption
  • Discrimination and Harassment
  • Equal Employment Opportunity
  • Ethics/Business Conduct, including Non-Retaliation
  • Gifts and Hospitality
  • Internal Investigations
  • Privacy of Personal Data
  • Protection of Confidential Information
  • Social Media

Metrics and Measurement

Measuring the impact of ethics and compliance initiatives is important in order to identify “lessons learned” and improve the effectiveness of the E&C program. Measurements also help JTI clients understand and demonstrate to others the return on their company’s investment in ethics and compliance. JTI supports our clients’ efforts to determine what to measure – and how – to gauge the results and added value of actions. Further, we counsel clients on the most effective approaches to communicating metrics and measurements, depending on the purpose and the audience.