How To Score Your Compliance Program Using Key
How to Score your Compliance Program usingKey Performance Indicators (KPIs), metrics,maturity ratings and other approachesLeslie BentonVice PresidentCREATe Compliance, an Ethisphere Business Ethisphere 2018. Confidential. Not for Distribution.CREATe Compliance works with enterprises to better manage internal and third party global riskfor key issues.CREATe Compliance’s services – CREATe Leading Practices – provide a practical and scalable wayto measure, improve, benchmark and monitor compliance and risk programs: CREATe Leading Practices for Cybersecurity – Aligned to the NIST Cybersecurity Framework CREATe Leading Practices for Anti‐Corruption – Aligned to leading international guidance andthe ISO 37001 Anti‐Bribery Management Systems Standard CREATe Leading Practices for Intellectual Property Protection CREATe Leading Practices for Trade Secret Protection21
Today we will discuss: KPIs vs MetricsDeveloping Useful KPIsHow KPIs Evolve with Program MaturityAvoiding Unintended Consequences3KPIs vs Metrics42
Key Performance Indicators (KPIs) and ComplianceWhat Are KPIs?Traditional Use of KPIsUse of KPIs in Compliance‐ A measure of businessperformance againstquantifiable goals‐ Financial and sales‐Measure effectiveness ofprograms‐As a monitoring tool‐Evidence of efforts beingmore than a paperprogram5KPIs vs MetricsKPIs – Strategic Value DriversMetrics ‐ YardsticksEvaluates whether an organization ismeeting important business objectivesObjective, quantifiable measures that areused to track the status of specificbusiness processesKPIs are derived from four elements: A defined program element Its goal or objective Components to reach the goal Defining success63
Developing Useful KPIs7What Makes a Useful KPI?KPIs Must beRelevant and ActionableBased uponProgram MaturityNew ProgramBasics are in place(e.g., policies,procedures controls)Sophisticated ProgramImplementation andeffective performance84
Developing Useful KPIsSharon J. Zealey, founding memberof NextGen Compliance LLC and former Global ChiefEthics & Compliance Officer of The Coca‐ColaCompany .recommends breaking down metrics intoa few different categories: Quantitative – numerical data such as trainingstatistics Qualitative – measures of effectiveness Process – efficiency or productivity Practical – interface with existing companyprocesses or functions Directional –whether the organization is gettingbetter at a process, activity or task Input – resources necessary to reach the goal9How KPIs Evolve withProgram Maturity105
Program Maturity12345MatureSystems well‐SystemsLimitedLittle or nosystemdevelopedapproachrepeatable systems withimplementedandinconsistent adopted, butprocesses,implementati development consistently internally andlimitedimplemented continuallyandawareness of on, primarilyimplementati and improved improvedreactiverisks, reactivethrough aon andregularimprovementmanagementefforts areprocessinconsistent11Putting KPIs into Action World’s largestbaking company 32 countries 22 subsidiariesYear 1 ‐ KPIs Within fourmonths, train morethan 83,000 of the113,000 associates Within a year –train 100% ofassociates126
Putting KPIs into Action – Policies and ProceduresKPI: Relevant policies andprocedures exist to detectand prevent briberyPotential Metrics: Anti‐corruption policies meet relevantrequirements and the company’s risk profile; Procedures outline how policies should befollowed; Policies and procedures have been translated intolocal languages and are accessible to employeesand business associates13Putting KPIs into Action – Risk AssessmentKPI: The company has assessedits corruption risk andaligned its program withthose risksPotential Metrics: The company performs and documents an annualanti‐corruption risk assessment that includes theelements identified in the FCPA Resource Guide The company has executed a plan for testing itspolicies, procedures and controls based on theassessment findings All findings that pose more than a low risk areaddressed within six months147
Putting KPIs into Action – Training and Capacity BuildingKPI: The company trainingprogram includes trainingtailored to businessfunction or riskPotential Metrics: 100% of employees responsible for managingvendor relationships have received specializedtraining All employees engaged in a high‐risk activity(sales, finance, government contracting) havereceived specialized training and passed a post‐training test with a score of 90 %15Putting KPIs into Action – Corrective ActionsKPI: The % of corrective actionsrequired by seniormanagement are achievedin a defined timeframePotential Metrics: Corrective actions are completed by businessunits in 60 days or less, 60‐90 days, 90‐120 days,over 120 days Identified corrective actions are assessed byformal audit within six months168
Avoiding UnintendedConsequences17Avoid Incentivizing Unwanted BehaviorExamples:Steps to Mitigate RisksExcessive pressure onteams to sell productsUnrealistic salestargets Embed compliancewithin organizations‐ Case in point:Wells Fargoemployees signingup fake accounts‐ Case in point:Toshiba seniorteams inflatingprofits Show leadershipcommitment Analyze targets inlight of risks andoperations189
Thank YouLeslie BentonLbenton@CREATeCompliance.com Ethisphere 2018. Confidential. Not for Distribution.10
KPI: The company has assessed its corruption risk and aligned its program with those risks Potential Metrics: The company performs and documents an annual anti‐corruption risk assessment that includes the elements identified in the FCPA Resource Guide
2019 Sender Score Benchmark 2 returnpath.com TABLE OF CONTENTS Page 3 Introduction Page 4 Percentage of Send Volume by Sender Score Band Page 5 Average Complaint Rate by Sender Score Band Page 6 Average Unkown User Rate by Sender Score Band Page 7 Average Spam Trap Count by Sender Score Band Page 8 Average Delivered Rate by Sender Score Band Pages 9-10 Inbox Placement Rate by Sender Score at .
The result is your total score on the SAT practice test, on a scale of 400-1600. 1 Total Score Scale 2 Section Scores Scale R W M 1 2 M 1 2 M T Score Your total score on . the. SAT practice test . is the sum of your Reading and Writing section score and your Math section score. Use the worksheets on . pages 4 and 5 to calculate your . section .
The result is your total score on the SAT practice test, on a scale of 400-1600. 1 Total Score Scale 2 Section Scores Scale R W M 1 2 M 1 2 M T Score Your total score on . the. SAT practice test . is the sum of your Reading and Writing section score and your Math section score. Use the worksheets on . pages 4 and 5 to calculate your . section .
Individual gun club score sheets may vary . Score Sheet Overview The official score is the record kept on the score sheet furnished by the gun club or the ATA. The score sheet gives an account of the ruling for each scored target in the event. The official score sheet must be available for shooter inspection at all times. The score sheet is .
When a basket is scored, please record the score on the flip chart or the electronic score clock. Please check with the score keeper often to confirm that the score you have indicated on the flip chart or electronic score clock corresponds with the official running score on the score sheet. 1.1.10 Time Out
Permutation Score Histogram vs Gaussian score Frequency 40 60 80 100 120 0 200 400 600 800 1000 * ue Score: 7.9 σ * m Score: 5.7 σ 31 Red curve is approx fit of EVD to score histogram – fit looks better, esp. in tail. Max permuted score has probability 10-4, about what you’d expect in 2x104 trials. True score is still moderately unlikely .
The most important score on the GMAT is the total score, which ranges from 200 to 800. This score is the GMAT result that schools look at primarily. The population of these scores follows a standard distribution: most students score near the mean score, and more than half of all GMAT test takers score within 100 points of 550, the median score.
Conners 3 ADHD Index Instructions: 1. For each item listed below, transfer the circled score from the Scoring Grid into the Item Score row. 2. Transpose each score by following the Transposing Rule and enter the score into each Transposed Score box. 3. Sum the transposed scores to obtain the Total Transposed Score, then circle this score in the .
