E.   Training & Education 

Ensuring that personnel are aware of their responsibilities related to the company's principles, practices and liabilities in international transactions is essential to implementing and maintaining an accountable anti-bribery compliance program.  The training and education component of the compliance program is intended to create that awareness. Keep several significant factors in mind when developing the program.  Train and educate all personnel, especially those in positions key to preventing or correcting possible violations that could prove to be costly to the company if not addressed. Employ qualified individuals, whether internal or external to the company, to provide compliance training and education services.  Many commercial providers that are experienced in providing such services and are well versed on the subject matter.  Use methods to train and educate that best suit the size and structure of the company and the various levels of knowledge and responsibilities of personnel. Although person to person communication usually is more effective, the instructional material can be effectively communicated orally and in writing via video, the internet or through the use of other forms of technology available to the company.  Reinforce the importance and expand the scope of awareness of the company's anti-bribery compliance program by updating the training and education of existing employees and by incorporating the information into orientations for new employees.  Identify and publish within the company the names and telephone numbers or e-mail addresses of primary training and education program contacts.  Keep records of the training and education services provided.  The following resources could be useful to your company.

Some companies provide promotional items or job aids as give-a-ways at training sessions to publicize a compliance program and the “hotline”.  The give-a-ways may include pens, keychains, calendars, screen savers, or laminated cards with a reminder message. 

See Sample Training Materials for examples of PowerPoint training materials from three small to medium sized companies and two large companies.

Law firms, accounting firms and consultants are among the many sources that can provide or develop training materials for a company.  Transparency International can provide access to experts and government agencies may provide speakers on the FCPA or the Federal Sentencing Guidelines.  Many professional organizations, such as ACI and ABA (American Bar Association), offer courses, seminars and conferences. 

See On-line Training Services for some commercial providers of training materials.

Sample Training Materials: examples of slide presentations (power point) from three small to medium sized companies and two large companies.

Due Diligence US Regulatory Issues US Foreign Corrupt Practices Act

Bribery and Corruption

Business Integrity & Accountability FCPA Record Keeping and Internal Control Best Practices

International Legal Issues Sales Reps & Export Controls

General FCPA

Law and Policy Against Improper Payments to Foreign Government Officials

On-line Training Services for some commercial providers of training materials.

On-Line Anti-Corruption Training Services

·; Interactive Dialogues www.interactivedialogues.com UK tel. 32 (0) 23530200).

·; LRN, The Legal Knowledge Company www.lrn.com tel. 1-800-529-6366).

·; Midi, Inc. www.eyeonintegrity.com  tel. 609-924-4817)

Anti-Corruption Training Videos

·      Commonwealth Films, Inc. www.commonwealthfilms.com  tel. 617-262-5634)

Various Courses and Training Materials

·; Practicing Law Institute http://www.pli.edu/

·; Bureau of National Affairs http://www.BNA.com/

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