David T. Gagner

1
Third Party Online Training and Whistleblower
Protection
David T. Gagner Vice President Internal Audit The
Standard Register Company
Wright State University Third Business Integrity
Breakfast Dayton, Ohio June 15, 2005
2
Third Party Online Ethics Training and
Whistleblower Protection

• Assessment of SR Training Program
• Frequency
• Subject Matter
• Required Signature
• Ethics / Compliance Training Areas
• Management
• Administrative
• Sales
• Production
• Warehousing

3
Third Party Online Ethics Training and
Whistleblower Protection

• Options
• Classroom Setting
• Self Taught
• Books, Articles, Etc.
• Web-based
• Pros / Cons
• Cost (Staffing, Travel, Etc.)
• Logistics (Scheduling)
• Flexibility

4
Third Party Online Ethics Training and
Whistleblower Protection

• LRN (The Legal Knowledge Company)
• Online Education and Training Delivered to
  Employees Desktops
• Advantages
• Available on Demand
• Delivers Consistent Message
• Customizable
• Automated Tracking

5
Third Party Online Ethics Training and
Whistleblower Protection

• Training Modules (SR)
• SR Code of Ethics
• Recognizing Conflicts of Interest
• Insider Trading
• Preventing Workplace Harassment
• Antitrust Talking with Competitors

6
Third Party Online Ethics Training and
Whistleblower Protection

• SR Program Includes
• 2 Modules Per Quarter
• 30 to 45 Minutes Per Module
• Quiz / Module Passing Grade 80
• Overall Compliance 90

7
Third Party Online Ethics Training and
Whistleblower Protection

• Mechanism for Reporting Unethical Activity
• Federal Sentencing Guidelines
• Sarbanes-Oxley Act
• Self Assessment of SR Program
• General Counsel / Internal Audit
• Number of Reported Complaints
• Associate Awareness of What to Do
• Trust / Anonymous / Intimidation

8
Third Party Online Ethics Training and
Whistleblower Protection

• THE NETWORK
• Trained Service Provider
• 1-800-xxx-xxxx
• Complaints Broken Down by Type
• On-screen Questions Vary by Type
• Formal Report (By Name or Anonymous)
• Structured Feedback to Caller

9
Third Party Online Ethics Training and
Whistleblower Protection

• Positive Results
• Increase in Reported Complaints
• 1-2 of Population
• Associates More Comfortable Reporting Issues
• Management Has Increased Awareness

10
Standard Register Company and IBI

• The Standard Register Company is one of the
  Corporate Founding Sponsors of The Institute for
  Business Integrity (IBI) at Wright State
  University in Dayton, Ohio