Compliance and ethics

Compliance training for people who decide on the company’s behalf.

Your code of conduct gets tested where compliance rarely is, like a procurement quote or the month-end close. The program takes the dilemmas into those teams and shows you what each one chooses.

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Quick answer

What is ethics and compliance training?

Ethics and compliance training teaches employees to apply the code of conduct, anti-bribery rules and internal policies in everyday decisions. Procurement works through the brother-in-law who shows up in a quote, sales works through the dinner a public official offers, and compliance gets a report on who took part and what they chose.

What stalls an integrity program

01
A signature only proves receipt.
The acknowledgment sits in the system. The decision about the supplier’s gift happens far away from it.
02
Values on the website, different behavior at work.
An MIT Sloan Management Review analysis of more than 1.2 million employee reviews found no correlation between the values companies state and how employees rate them on those values.
03
One event a year shows little.
Periodic training and communication are among the 15 criteria in Brazil’s Decree 11,129/2022 (art. 57, IV). A yearly course checks the box but says little about effectiveness.
04
Dilemmas arrive off script.
The real dilemmas show up in procurement, in sales and at month-end close, and a generic course was written for nobody in particular.

Mission examples

Situations we might write for this topic. In your program, they come from your own policies.

Sales · 2:05 pm

A little help with the tender.

A contact at a public agency offers to “speed up” the review of your bid in exchange for an expensive dinner. Do you keep talking or end it and tell compliance?

Mission 01

Procurement · 9:30 am

The supplier is family.

In a quote, a company owned by a colleague’s brother-in-law comes in with the best price, and nobody mentioned the relationship. Do you stay quiet or log the conflict of interest?

Mission 02

Month-end · 7:10 pm

“Just this once.”

You see a manager pressure a colleague to skip an approval step to close the month. Do you let it go or report it through the speak-up channel?

Mission 03

Dilemmas by department, written from your code

A dilemma map by department

We start from your code, your risk matrix and the questions your compliance team receives to choose the dilemmas for each audience.

Missions with a real decision

Each mission puts a decision in front of someone: the gift, the supplier who is a colleague’s relative, the invoice with the wrong date. The answer shows up right away, with the part of the code that applies.

Team seasons

Departments compete in mission cycles. The score is collective, and the conversation about the dilemma happens inside the team.

Leaders and champions

Managers get short scripts to discuss dilemmas with their teams. In the most exposed areas, champions answer questions before they reach compliance.

Evidence for audits

Reports on participation, choices and progress by department, organized to show periodic training and communication.

What we track

Participation by department
Choices per dilemma
Dilemmas with most doubt
Leader engagement
Champion engagement
Progress per cycle

Legal basis (Brazil)

Brazil’s Decree 11,129/2022, art. 57, IV ↗: Lists periodic training and communication about the integrity program among the criteria used to assess it. The decree regulates Brazil’s Clean Company Act (Law 12,846/2013).
Brazil’s Decree 11,129/2022, art. 56 ↗: States that an integrity program should foster and maintain a culture of integrity in the organization and be continuously improved.
Brazil’s Decree 11,129/2022, art. 23, V ↗: Proving that the company has and applies an integrity program can take up to 5 percentage points off the anti-corruption fine calculation. The maximum discount applies only if the program was in place before the wrongful act.

Frequently asked questions

01Is compliance training mandatory?

It depends on where you operate and on your sector. In Brazil, Decree 11,129/2022 uses periodic training and communication as a criterion to assess integrity programs, and a proven program can take up to 5 percentage points off the anti-corruption fine calculation, in full only if it existed before the wrongful act. If you have a program, you need to show it works.

02Which topics should compliance training cover?

Start from your code of conduct and your risk matrix. Common topics are conflicts of interest, gifts and hospitality, anti-bribery, dealing with public officials, accounting records, speak-up channels and, where relevant, privacy and harassment.

03How do you get the code of conduct read and practiced?

Write each rule as a situation people recognize from their own work, and ask them to decide. Then repeat it in different formats throughout the year. qlture does this with missions, department dilemmas and leader conversations.

04What is the difference between compliance and integrity?

Compliance is the function and the practices that ensure laws, regulations and internal rules are followed. Integrity is broader: Brazil’s Decree 11,129/2022 talks about fostering a culture of integrity. A good program covers both the rule and the behavior.

05How do you measure the effectiveness of compliance training?

Track choices in real dilemmas, participation by department, topics with the most doubt and progress between cycles. Completion rates go into the report as context.

Shall we put this
into practice?

Tell us which policy people sign and then ignore. We design the program with you.