In a news release, ELT said the survey also found that almost 60% of employers are currently not offering such training to their employees. Of the employers that are conducting ethics and compliance training, 26% are holding informal training sessions, such as briefly discussing and distributing a Code of Conduct during a staff meeting. The FSGs only permit this kind of informal training for employers with less than 200 employees, while employers with more than 200 employees must provide more formally planned and implemented training programs, according to the release.
Nearly half of those who are conducting ethics and compliance training (47%) are not tracking and archiving training completion records, even though, under the FSGs, employers can substantially mitigate potential fines and punishment for criminal violations if they can prove that they have an effective ethics and compliance program in place.
Thirty percent of respondents surveyed have not published a Code of Conduct or Code of Ethics, which is required of companies listed on the NYSE and NASDAQ, and strongly encouraged for all publicly traded companies under Sarbanes-Oxley.
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