Developing an Integrated
Anti-Fraud, Compliance, and
Ethics Program
Conducting Anti-Fraud, Compliance,
and Ethics Training
© 2017 Association of Certified Fraud Examiners, Inc.
Discussion Questions
1. Do employees in your organization receive
formal compliance and ethics training? If so,
how is it conducted? Do all employees receive
the same training, or is there any variation in
content or presentation?
2. What information do your employees get
regarding fraud risks and procedures for
reporting suspected fraud? What methods are
used to disseminate this information?
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Introduction
 The training program should
be used to educate
employees about why
ethics and compliance
matter—both to the
organization as a whole and
to them as individual
employees.
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Can Ethics Be Taught?
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Benefits of Effective Training
 Reinforces the organization’s:
• Commitment to ethics and compliance
• Strong anti-fraud stance
 Empowers employees and results in better
ethical decision making
 Increases compliance and reduces violations
 Fosters a culture of trust and honesty
 Improves employee morale and increases job
satisfaction
 Increases the quality of tips received
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Benefits of Effective Training
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Common Training Challenges
Source: NAVEX Global’s 2015 Ethics and Compliance Training Benchmark Report
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Planning the Training
 Define the training needs.
• Assess the current knowledge base.
• Determine the ideal knowledge base.
• Use training to fill the gap between these points.
 Outline the learning objectives.
• They must be clear, specific, and measurable.
• They must describe what learners will be able to do
because of the training, not just what they will know.
• “Following this training, employees will be able to …”
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Selecting the Target Audience
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Organization-wide training
Segmented or targeted training
Executive training
Middle-manager training
Training for board of directors
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Selecting the Training Methods
Live,
instructor-led
training
Workshops
Prerecorded
presentations
Online or
computerbased training
Mobile
learning
Game-based
learning
Micro-learning
Blended
learning
So what is the best option?
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Determining the Training Frequency

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Frequent exposure is key.
Train at the time of hire.
Provide refresher training at least annually.
Provide additional training when policy changes
are made.
 Provide additional training when issues reveal
that it is desired or necessary.
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Developing the Training Content
 Content should be developed in-house by staff
who have:
• Expertise in the organization’s compliance and
ethics risks
• Experience in employee training
 Tailor content to the organization and the
audience.
 Focus on highest-risk areas.
 Include both compliance and values-based
ethics training.
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Developing the Training Content
 Include a discussion of
the organization’s codes
and policies that support
the compliance and
ethics program.
 Include sections on
specific risks (e.g.,
conflicts of interest,
government contracting,
FCPA).
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Developing the Training Content
 Provide information on how and why to engage
in ethical behavior:
• The connection between compliance, ethics, and fraud
• What to do and what not to do—how to understand
and interpret the company’s codes, policies, and
ethical expectations
• How to make ethical decisions
• Where to turn for ethical guidance
• How to report suspected unethical behavior or
compliance violations
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Developing the Training Content
 Include targeted anti-fraud training:
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•
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What fraud is and what it isn’t
How fraud hurts the organization
How fraud hurts employees
Who perpetrates fraud
How to identify fraud (common financial, transactional,
and behavioral red flags)
• How to report fraud
• The punishment for fraudulent acts
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Administering the Training
 Use actual case examples.
 Use cascading training.
 Address geographical variations:
• Language
• Timing and presentation approach
• Cultural factors
 Require employees to certify attendance.
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Reinforcing the Training
 Provide continual exposure to compliance and
ethics messaging:
•
•
•
•
Posters
Newsletters and blogs
Dedicated section on company intranet
Responsive resource for advice (e.g., “Ask the
CECO,” or dedicated discussion forum)
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Evaluating the Training
 Solicit participant
feedback.
 Assess training
effectiveness.
 Review training records
when issues arise.
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