"The better job we do meeting our compliance obligations, the more successful we are as a company."
– Mike Szymanczyk, Chairman & CEO, Altria Group
Measuring & Evaluating
Our Compliance & Integrity Program includes multiple measurement and evaluation tools to assess performance across Altria and its companies. These surveys, audits and assessments identify possible areas of improvement enterprise-wide as well as at the business-unit level.
- Compliance Audits - To help keep the compliance program on track, the Corporate Audit department supporting all of Altria’s companies performs periodic reviews of certain compliance and integrity initiatives. This includes program implementation, internal communications and training, allegations and investigations, as well as policy-specific compliance reviews at selected locations.
- Progress Updates - Altria’s Chief Compliance Officer provides periodic reports to Altria Group’s Board of Directors to share updates on initiatives and performance related to compliance.
- Allegations and Investigations Measures - We systematically capture quantitative measures of efforts and outcomes, including number of allegations; the nature of these allegations; the anonymity rate of complaints; substantiation rates; and disciplinary actions. Our companies investigate all allegations of non-compliance. If allegations are substantiated they are addressed as appropriate, including training (or re-training) and employee discipline.
- Compliance Training Measures - We capture various metrics to track training completion and effectiveness. We track employee completion rates and share this information with company leaders, who use it to encourage timely completion of compliance training with employees. On average, we achieve 98 percent completion. We also measure training effectiveness through knowledge checks incorporated in the training modules. We solicit employee feedback at the end of the course and 90-100 days after the course to assess if the course met its objectives, whether it was a good use of the employees’ time and whether employees applied course teachings on the job.
In 2011, Altria delivered two enterprise-wide training modules on the topics of FDA/Regulatory Affairs and Code of Conduct. Below are the employee survey scores:
- Employee Survey - We periodically survey employees of Altria’s companies to evaluate progress over time in building a strong culture of compliance. These surveys capture robust quantitative and qualitative measures. This employee feedback helps identify key focus areas for continuous monitoring and improvement.
Between 2009 and 2010, more than 4,600 salaried employees of Altria and its companies responded to a compliance survey. The survey results were strong and encouraging. In key areas, our scores improved or remained at high levels when compared to previous surveys we did in 2004 and 2006. Some results compare favorably to other companies as measured by the National Business Ethics Survey (NBES) conducted by the Ethics Resource Center (ERC).
We are encouraged by these survey results and believe that our system is making good progress against our goal of having all employees committed to our culture of compliance.
We continue to improve our compliance system. The survey identified some opportunities, based on the ERC benchmarks, to implement new programs and communications to build employees’ trust in Altria’s compliance system, especially around understanding their compliance obligations, building their comfort in reporting potential compliance violations and communicating the serious stance the company takes against retaliation. For example, we developed the Trust the System video that depicts a situation where potential wrongdoing occurred, how two different employees handled it and how management addressed the situation. It touches on retaliation and addresses the concern that no one will act when allegations are communicated; it demystifies the HelpLine and the reporting process by depicting how it works and what happens when concerns are reported; and it also builds awareness of the other alternatives for reporting.
In 2012, Altria will survey its employees to assess organizational culture, the effectiveness of its compliance program and related tools and employee engagement. The survey will be companywide and involve employees at all levels.
2011 KEY ACCOMPLISHMENTS
- Launched Altria’s refreshed Code of Conduct improving readability, length and tone. All employees received a copy of the Code through their management, who discussed compliance and reinforced the importance of using the Code of Conduct to support Altria’s Mission & Values.
- Rolled out new scenario-based Code of Conduct training for salaried and hourly employees. Company management facilitated the classroom training for hourly employees.
- Updated the company’s employee performance ratings to provide a greater emphasis on building a culture of compliance and more directly tie an employee’s performance review to compliance-related activities.
- Launched a Conflict of Interest certification campaign for all salaried employees asking them to certify that they either have no potential conflicts of interest or that they have disclosed any potential conflicts of interest.
Key Measures from 2011
- Altria and its companies delivered 19,280 instances of web training
- Altria and its companies delivered 4,200 instances of classroom training
- Employees completed 24,500 hours of compliance training
