BNSF Ethics and Compliance Program
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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;
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
Code of Conduct
Company Policies
Risk Assessment and Mitigation
Design and Implementation of Compliance Plans
Communication
Training
Monitoring Effectiveness / Internal Audit Coordination
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Code of Conduct
Highlights Employee’s
Obligations and
Expectations
Q&A to Reinforce Education
Online Annual Certification
Conflict of Interest and
Other Reporting
Requirements
Links to Policies
Leaders’ Guide
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Policy Management
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
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
Corporate Audit Services – Annual Audit Plan
Fraud and Controls Meetings
Employee Hotline
Conflict of Interest Reporting and Tracking
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Specific Compliance Issues
Acceptance and Giving of Gifts
Political Contributions
PAC Activities
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