Ethical training and certification

1) Purpose and principles

The goal is to create a sustainable culture of ethics and compliance, where employees and partners make decisions given the law, policy and ethical implications for customers, society and brand.

• Tone from the top: leadership demonstrates personal responsibility.
• Relevance by design: learning for role and jurisdiction tasks.
• Practice over theory: cases, simulations, dialogues, error analysis.
• Measure & attest: measurability, certification, trigger updates.
• Zero retaliation: whistleblowing.

2) Scope (ethical domains)

Code of Conduct and Values.
Anti-corruption/anti-bribery (ABC), gifts and hospitality, conflicts of interest.
Privacy and data: legality of processing, minimization, DSAR, honesty in data.
Marketing and communications: no misleading offers, honest promotional mechanics.
Responsible play/responsible consumption (if applicable).
Equity and inclusion: anti-discrimination, accessibility, equal opportunity.
Ethics of AI and algorithms: transparency, absence of harmful biases, explainability, human control.
Payment honesty: prohibition of manipulations with payments, correctness of limits and checks.
Interaction with regulators and auditors: completeness and truthfulness of materials.
Working with suppliers and affiliates: supply chain ethical standards.

3) Roles and RACI

(R — Responsible; A — Accountable; C — Consulted; I — Informed)

4) Curriculum (by role and jurisdiction)

• Code, anti-corruption/conflicts of interest, anti-discrimination.
• Data privacy and security for non-technical roles.
• Communications/Marketing: Honesty and Limitations.
• Communication channels (ethics line), prohibition of repression.

• Engineers/Data/AI: secure coding, data integrity, ethics of A/B tests, fairness/exploit, logging and audit of algorithms.
• Finance/Payments/AML: ethics of investigations, "do no harm to the client," rights and transparency of returns, lack of incentives for abuse.
• Operations/Support: fair settlement of claims, clear language, empathy, de-escalation.
• Marketing/Affiliates: reliability of materials, age restrictions, prohibition of "dark patterns."
• Management: "tone at the top," conflicts of interest, fairness of decisions, ethics of goals/bonuses.

5) Training formats

Micro-modules (5-10 minutes), mobile-accessible.
Scripts and simulations (branching dialogues, "choice with consequences").
Workshops/discussions on complex cases.
Narrative cases based on real incidents (depersonalized).
Monthly "ethical minutes" at team meetings.
Just-in-time reminders (banners in products/tools, tips in forms).

6) Certification and recertification

Primary onboarding certification (30 days).
Annual recertification + triggers (law/policy changes, role/country).
Pass threshold: ≥ 85% (critical topics - 100%). Non-pass → retry, notify manager.
Read- & -Attest - Confirm Code/Policy Familiarity.
Mapping in LMS/GRC: each topic → associated policies/controls → evidence.

7) Content (minimum by section)

Code and values: conflict of interest, gifts/invitations (limits, registration), secondary employment, insider information.
Anti-corruption: prohibition of bribes/greases, "red flags," intermediaries.
Privacy/data: legality, minimization, subject rights, transparency, secure analytics.
AI ethics: data sources, consent, bias/fairness, human-in-the-loop, decision logging, right to explain.
Marketing/responsible play: fair offers, audience restrictions, protection of vulnerable groups.
Ethics of investigations and sanctions: proportionality, procedural guarantees, documentation.
Whistleblowing: anonymity, protection from reprisals, processing times.

8) Assimilation assessment

Quizzes after modules, situational questions, open answers.
Practical tasks (setting up configs/analyzing the case/writing a correct answer to the client).

Behavioral indicators: the share of ethical decisions in simulations, a decrease in "red flags."

Pulse surveys (ethical climate, trust in message channels).

9) Integrations

LMS ↔ GRC: automatic creation of tasks for recertification; storing certificates as evidence.
HRIS: pass statuses in employee files, KPI/bonus conditions.
Service Desk: violation tickets, CAPA, training on results.
Policy Repository: direct links to current versions, read-attest.
Risk/KRI: incident/complaint alarms → exchange rate updates.

10) Metrics and KPIs

Completion Rate (by role/country) - target ≥ 98%.
On-time Completion - the proportion of those who completed the deadline (target ≥ 95%).
Assessment Score p50/p90 - quality of assimilation.
Refresher Lag - delay between policy change and training.
Whistleblowing Trust Index - the proportion of requests processed without reprisals and on time.
Ethical Incident Rate - frequency of ethical violations (per 100 employees).
Repeat Findings - repeated comments on ethical topics (12 months).

11) Dashboards

Training Coverage: Coverage/delinquencies by jurisdiction/role.
Risk-linked Curriculum: what risks are covered/" holes "left.
Incident → Course Mapping: which courses are updated based on incident results.
Assessment Quality: distribution of points, difficult questions.
Whistleblower Flow: reaction/closing time, no retalia.

12) SOP (standard procedures)

SOP-1: Course Design

Signal/demand → definition of audience and goals → scripts and cases → review Legal/DPO → pilot → release in LMS.

SOP-2: Recertification

Automatic creation of tasks 30 days before the deadline → reminders → escalation to managers → a report in GRC/HR.

SOP-3: Update on Incident/Law

Post-mortem/legal update → editing content → communication → mandatory "refresher" for affected roles.

SOP-4: Message Channels

Case acceptance → registration → anonymity protection → CAPA → investigation → feedback to the applicant (if possible).

13) Artifact patterns

13. 1 Pass certificate (minimum):

Employee ID/role/jurisdiction, courses and date, score/threshold, next recertification date, LMS signature, hash receipt.

13. 2 Gift/Conflict of Interest Log:

Date, party, description, cost/estimate, decision (allowed/rejected), owner, policy links.

13. 3 Case card (ethics case):

Context → decision options → path chosen and rationale → implications → linkage to policy/control.

14) Ethical line and protection from repression

Multilingual channels (web/phone/mail/messenger).
Anonymity, response time slots, public metrics without personal disclosure.
Mandatory "how to report and what to expect" training module.
Zero tolerance for repression is a separate policy and register of cases.

15) Antipatterns

"Put a tick": video without cases and practice.
Same course for all roles/countries.
No connection to incidents/risks/policies.
Assessment "for the species" without threshold and retests.
Lack of whistleblower protection.
One-time campaigns without recertification and updates.

16) Maturity model (M0-M4)

M0 Hell-hoc: one-off lectures, no measurability.
M1 Planned: basic courses, pass accounting.
M2 Manageable: turmeric by role, thresholds, dashboards, read-attest.
M3 Integrated: risk/incident linkage, trigger updates, certificates as evidence (WORM).
M4 Continuous Ethics: simulations, behavioral metrics, AI recommendations, automatic refresher course planning.

17) Related wiki articles

Policy and compliance repository

Policies and Procedures Lifecycle

Communication of compliance solutions in teams

Tracking legal updates

KPIs and compliance metrics

External checks and re-audit

Storage of evidence and documentation

Result

Ethical training and certification is not a formality, but a manageable system of behavior: role relevance, practical cases, measurability and secure feedback channels. Such a system strengthens the trust of customers and regulators, reduces the risk of violations and makes the culture of ethics a competitive advantage.