Beyond “Check the Box” Intermediary Compliance Training Programs

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Delivering anti-corruption training to intermediaries is a tough gig. Jim Nortz explores the importance of engagement and dialogue in compliance training.

Read Part 4 here.

The general counsel for our Asian operations was a very impressive man. He was among the first 400 attorneys licensed in China following the death of Chairman Mao Zedong. Later, he also obtained a law degree in the United States and became licensed to practice in Ohio. He did an extraordinary job supporting our businesses in China, Japan, Hong Kong and Taiwan, and he strongly advocated ethical business practices both internally and with our Intermediaries. So, I was very interested in witnessing first hand his annual anti-corruption training program for 40 of our largest third-party distributors in China who we had assembled in a hotel ballroom in Shanghai.

Because our general counsel delivered his training presentation in Chinese, I could not understand a word of what he said. But as he droned on in a monotone for 45 minutes, I knew for certain that the training session failed to have the desired effect. Shortly after he took the podium, I noticed that no one was paying attention to him. Instead, the intermediaries in the audience were looking at their computers or their phones or were having lively conversations with one another. Although…

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