Ocyan incorporates pioneering behavioral risk assessment into its compliance system

Ocyan has launched a pioneering training program for its Ethics Agents, who are volunteer in-house opinion makers that support the company’s compliance efforts, for studying and evaluating human behavior predictively. The initiative will enhance the Compliance System of Ocyan, whose partnership with the Institute for Behavioral Risk Research (IPRC) will train these agents to conduct behavioral risk assessments of team members.

“The project is a way to anticipate risks to support prevention efforts and will study human behavior. The first module of the course is in final phase and, by December, all agents will have completed the training program,” explained Gilberto Couto, Ocyan’s Chief Compliance Officer (CCO).

The IPRC courses comprises three modules to further understanding of the behavior of people who perpetrate fraud and to better understand discrimination in connection with diversity, as well as corporatism and the pillars of a people-focused compliance program. “By the end of this first edition, we’ll have 30 Ethics Agents ready to support the company in detecting relevant behaviors. We understand that the human factor is the source of all and any threats to organizational integrity”, said Couto.

IPRC already has worked with Ocyan on other internal training programs and, for this year, the Institute plans to multiply the new ideas throughout the company. “We want Ocyan’s Ethics Agents to better understand behavioral risk to improve their identification capacity and to give them tools to act as agents who strengthen the culture of compliance within the company,” said Renato Santos, founding partner of IPRC.

The training methodology for the Ethics Agents consists of a 20-hour e-learning course and an 8-hour on-site course in each module, for a total of 45 days of classroom activities.  By the end of the first module, the agents are challenged to create a project for Ocyan’s Compliance Department. After completing the second and third modules, the agents then have to put the project into practice.

“Once we complete the first cycle, we plan to further expand the group’s training activities next year to further improve our compliance environment.  Training our Ethics Agents to identify, interpret and classify the various factors that result in deviations in behavioral conduct is another step we are taking to consolidate Ocyan as a company that acts ethically, with integrity and solid moral values,” concluded Gilberto.

Compliance at Ocyan

In 2016, the kick-off came with the creation of the Compliance Policy and the increase in the number of team members in the department. In 2017, the company restructured the Ethics Line channel, which completed two years in April and already has received 275 reports of attitudes inconsistent with the internal rules of conduct and current laws and regulations. During this period, 43 disciplinary measures were applied, which included termination, verbal and written warnings, suspension, feedback and the blocking of suppliers in the company’s registration.

In early 2018, Ocyan created the Ethics Agents program by appointing select team members to act as compliance ambassadors for the company. The measures to enhance compliance have contributed so that, in July 2018, Ocyan was included once again in the supplier registry of Petrobras. Also, in September last year, the company signed, along with 13 other relevant oil and gas companies, the Oil Industry Integrity Pact, which aims to create a more ethical and transparent market.

At year-end, the company launched a training program specifically  for suppliers with medium, high and critical risk in an e-learning format, whose goal is train them in the concepts set out in the Anti-corruption Law and Ocyan’s Third-Party Code of Conduct, as well as to orient them with regards to the behaviors expected in their relationship with the company.