Transcript BNSF Ethics and Compliance Program

BNSF Ethics and Compliance Program
Roger Nober
Executive Vice President Law and Secretary
July 13, 2011
BNSF’s Ethics and Compliance
Program
KEY COMPONENTS

Tone of Management

Program Design and
Implementation

Employee
Communication and
Training

Monitoring
Effectiveness
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Culture of Compliance
Annual
Plan
Personal
Objectives
Initiatives

Tone at the Top
Leadership Model

Vision and Values

1-3 years
Strategies
3+ years
Vision & Values
and Leadership Model
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Tone at the Top
Tone at the top is a visible willingness by senior
management to let values drive decisions to prioritize
those values above other factors – including financial
results, and to expect all others in the organization to
do the same.
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Chief Compliance
Leadership
ModelOfficer Function
VISION:
Annual
Plan
Personal
Objectives
Initiatives
1-3 years
Strategies
3+ years
Vision & Values
and Leadership Model
Our vision is to realize the
tremendous potential of BNSF by
providing transportation services that
consistently meet our customer’s
expectations.
VALUES:
Shared Values, Style, Community,
Liberty, Equality, Efficiency
LEADERSHIP MODEL
• Create a Compelling Vision
• Model the Way
• Lead More; Manage Less
• Communicate, Communicate,
Communicate
• Make Development a Priority
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Compliance Program Strategy
While primarily focused on preventative measures, a formal
compliance and ethics program also:


Minimizes the impact of unethical behavior on company
operations and financial performance;
Provides consistency in applications of higher standards of
conduct company wide;
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Enhances and safeguards the company’s reputation;
Provides business and brand benefits;
Builds customer trust and loyalty;
Facilitates acquisition and retention of talent; and

Demonstrates commitment to global responsibility.
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Compliance Program

Chief Compliance Officer
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Code of Conduct
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Company Policies

Risk Assessment and Mitigation
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Design and Implementation of Compliance Plans

Communication

Training
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Monitoring Effectiveness / Internal Audit Coordination
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Code of Conduct

Highlights Employee’s
Obligations and
Expectations
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Q&A to Reinforce Education
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Online Annual Certification
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Conflict of Interest and
Other Reporting
Requirements

Links to Policies

Leaders’ Guide
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Policy Management
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Policy on Policies
Review and Approval Process
Annual Review
Ensure consistency and clarity of policies
Communicate employee obligations effectively
Monitor Effectiveness through training and enforcement
Document exceptions
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Communication and Training

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
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New Employee Orientation
Learning Management System
Online Annual Certification
Web-Based Training
Live Training
Leaders’ Guide
Policy Communications – BNSF News
It takes 20 years to build
a reputation and five
minutes to ruin it. If you
think about that, you’ll
do things differently.
~ Warren Buffett
Leaders’ Guide
A guide to answer some common compliance and
ethics-related questions
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Monitoring Effectiveness

Assessing Risk – Enterprise Wide Risk Assessment
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Corporate Audit Services – Annual Audit Plan
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Fraud and Controls Meetings
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Employee Hotline
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Conflict of Interest Reporting and Tracking
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Specific Compliance Issues
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Acceptance and Giving of Gifts
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Political Contributions
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PAC Activities
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