Learning Gap Analysis

The Federal Sentencing Guidelines list training as one of the seven required elements of an "effective compliance and ethics program."  According to the Guidelines,

The organization shall take reasonable steps to communicate periodically and in a practical manner its standards and procedures, and other aspects of the compliance and ethics program, to [all personnel] by conducting effective training programs and otherwise disseminating information appropriate to such individuals' respective roles and responsibilities.

If the plain language of the statute is not enough, the Commentary to the Amendments make clear that compliance and ethics training is required. Specifically, the Commentary states:

Section 8B2.1(b)(4) makes compliance and ethics training a requirement, and specifically extends the training requirement to the upper levels of an organization, including the governing authority and high-level personnel, in addition to all the organization's employees...

In addition to the Federal Sentencing Guidelines, various other laws, cases, and regulations require or encourage training on ethics and compliance topics.

Compliance and ethics training is not a "one-size-fits-all" solution. Brightline Compliance will ensure that your training is customized to the needs of each individual employee. First, Brightline's nationally-known attorneys will create a risk analysis of your training needs. Specifically, they will examine your Ethics Code of Conduct and other relevant policies and look at factors such as your industry, the states where you have employees, and the job functions of your employees. Brightline will then provide you an analysis of the topics on which you need to train employees and which employees need which type of training.