Code of Conduct Training - A Long Term Strategy for Pharmaceutical Companies

The Challenge


In 2008 a newly formed Global Compliance Team were given the task to establish, drive and embed a culture of ethics and integrity at a leading Pharmaceuticals company. A key objective was to:

Improve compliance behaviours through effective training and support

A new Code of Conduct was implemented, providing the framework for consistent policy standards for all employees. For the first time the whole organisation would be held accountable, globally and cross-functionally, against one Code of Conduct. As a result, the company needed to develop and deliver Code of Conduct awareness training to 65,000 employees worldwide.

After conducting a rigorous benchmarking process to provide insights into what kind of solution and format they should use for training, the company decided to use eLearning as the key delivery method. They chose to partner with SAI Global to develop and deliver a bespoke eLearning solution.

The importance of dedicated Project Management

The eLearning was developed with input of over 125 stakeholders worldwide from different parts of the business. Project management was therefore an essential element of the planning, development and delivery. Both SAI Global and the client employed dedicated project managers to keep the project on track and to identify and resolve potential issues throughout the project.

Instructional Design

The instructional design process played a key part in identifying and overcoming potential content issues. It was essential that the design of the programme was based on clearly defined learning objectives. The programme also needed to take into account adult learning theory, appeal to different learning styles and cultural differences. By adopting a modular and scenario-driven approach, many of these issues were overcome. Profiling was also used to create stranding of content for each learner, to ensure that the training was appropriate and relevant to each job role at the company.

Developing the eLearning Solution

The training was split into three key elements that would span a three-year delivery programme. Each year the training would build on employees knowledge from the previous year, and help to enhance behaviours and attitudes towards the Company Code of Conduct.

Pilot Implementation

A pilot programme for approximately 500 people from a cross-functional and globally dispersed group of employees was undertaken within the company. At the end of the pilot a combined training evaluation and technical questionnaire was sent to all participants. The feedback on the eLearning content was very positive and resulted in minor amendments. Any technical issues were identified and rectified prior to the full rollout across the business.


Through the LMS database and manual tracking processes, the company has had over 99% of all active, permanent employees trained on the 2008 and the 2009 courses. The rollout of the 2010 course started on July 1st and will complete at the end of the year. There is an ongoing process to train new starters as they join the company.


  • Profiling of learner content provided relevant and appropriate scenarios that would resonate with end users
  • Internal and external benchmarking provided invaluable data on overall success and the specific development in employee awareness and understanding
  • Senior Management involvement and endorsement - helped to drive the message of compliance and integrity from the 'top-down'
  • Implementation was hugely successful and results demonstrate that end-users are getting real value from the programme


  • Dedicated project management is vital at both ends to keep the programme on track - from development right through to delivery
  • The importance of scoping and planning to identify training needs, key audience groups to be targeted and the appropriate delivery methods
  • A pilot programme is essential in order to pin-point any issues - helping to save time and money in the long-term
  • Aligning business objectives with learning objectives - this is invaluable to ensure that the learning solution really delivers what is needed within the business
  • Take a long-term view - the compliance landscape is constantly changing, solutions need to adapt and develop alongside this

About SAI Global Compliance

For twenty-five years, SAI Global Compliance clients have built stronger corporate cultures and more effective all-around programs with our compliance, risk management and governance solutions. With offices in more than 25 countries, SAI Global provides risk and culture assessments; Code of Conduct reviews, development and training; award-winning, innovative online training; training needs assessments; benchmarking and surveys; hotline, ethics reporting and case management solutions; risk- and region-specific updates, databases, regulatory alerts and newsfeeds; and technology solutions that integrate and connect all aspects of a legal or regulatory compliance program.