Establishing a culture of Ethics & Compliance in the workplace

Deloitte Legal Alert

In today’s rapidly changing and complex regulatory landscape, necessity in an informed approach to the business strategy complying with all the applicable laws and corporate policies is getting more important than ever. While no employee breaks the law knowingly, except for rare cases, a compliance failure typically occurs due to lack of knowledge and understanding. That is exactly why companies shall treat compliance training as highly crucial to the sustainability and success of their business.

Why compliance training is important?

Under the vicarious liability defined by regulations of extraterritorial reach, a company can be held liable for the actions of its employees who engage in unethical and questionable conduct, potentially resulting in the imposition of financial sanctions and leading to negative public scrutiny.

To defend itself against such liabilities, the company must prove that it had implemented adequate and effective measures to prevent any wrongdoing. Having relevant training in place is a demonstrable proof that the company has put reasonable efforts to warn employees about illegal conduct to avert non-compliance risks. 

How compliance training is delivered? 

Training materials shall be developed to reflect internal corporate policies and existing legal requirements (both Azerbaijani and those with extraterritorial reach e.g. FCPA, UK Bribery Act, GDPR etc.). 

As a procedural sequence in arranging the training, the company shall: 

• Divide participants into groups based on their engagement risk (i.e. high category includes management, procurement, finance, logistics; low category consists of office administrative staff, field engineers etc.)

• Conduct training through interactive sessions, making sure that the content is well understood;

• Following the training sessions, test the knowledge of participants;

• Issue certificates to those who successfully completed the trainings.

What is covered under compliance training?

The list of modules may vary depending on the nature of a particular company’s business and the risks inherent to the industry in which it operates, but the general compliance topics are as follow:  

• Anti-bribery and anti-corruption;

• Anti-money laundering;

• Personal data protection; 

• Export/import control;

• Anti-trust;

• Impartiality and conflict of interest; 

• Dealing with state officials; 

• Reporting non-compliance.

Deloitte Academy Azerbaijan offers customized compliance trainings conducted by experienced legal and compliance professionals.  Please contact us to discuss your particular training requirements.

Legal Alert on Ethics & Compliance in the workplace
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