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GRC Professional : GRC Summer 2012
31 HR process Compliance process Recruitment Pre-employment checks; ethical questions (to weed out those who will never fit into desired culture) Induction (new employees) Introduction of the Code of Conduct / Code of Ethics; training on compliance policies from outset Training and development Ongoing training of compliance / ethics requirements Engagement survey Incorporating culture of ethics and compliance questions to provide visibility on current culture HR feedback channel Whistleblowing / reporting of inappropriate behaviour Disciplinary committee Proper enforcement of compliance policies / Code of Conduct Exit interviews Potential source of whistleblowing reports on misconduct An integrated model In order to take full advantage of these synergies, AIA Group, the world’s largest independently listed pan-Asian life insurance group, was able to implement at the beginning of 2010 an integrated model involving the attachment of a team of human resource learning and development specialists to the compliance department. Although the team leader reported to the Head of Human Resources and the team was considered HR headcount, the team (the Compliance Learning Academy team) was fully dedicated to collaborating with the compliance department to implement key compliance and ethics learning initiatives. The business case for such an arrangement will not generally be an easy sell and many compliance heads would probably struggle to convince their human resources head to fully allocate no doubt stretched HR resources towards compliance department- directed initiatives. AIA Group was at the time undeniably in a rather unique situation: it had separated from AIG, its former US parent, and its shares were listed in a Hong Kong IPO in 2010. This required AIA Group to achieve a number of critical compliance and ethics awareness deliverables in a relative compact period of time. This requirement provided the rationale and justification that garnered management support to the compliance/HR arrangements. The 18-month partnership between human resources and compliance yielded many positive results. The first Group-wide AIA customised e-learning modules were created and implemented, including modules designed to ensure critical awareness of all staff of listing rules related policies (e.g . insider dealing, price sensitive information) prior to listing. The latter modules were rolled out with 100% completion by all staff in record time using the existing HR platform (at no incremental cost). Ethical leadership courses were launched for all Hong Kong-based corporate officers of the Group and rolled out to senior staff in a number of other countries. A creative and custom-made interactive intranet- based Code of Conduct Toolkit was launched to address frequently asked questions around the Code of Conduct and common compliance issues (such as what managers should do if they receive a whistle blowing report X It is therefore surprising that today, in many companies, the human resources and compliance departments do not commonly work closely together to help build a strong culture of ethics and compliance.
GRC Spring 2011
GRC Autumn 2012