Fiduciary Bootcamp
In an effort to provide all employees involved in Sun's reporting process and internal controls with
the necessary knowledge and education to understand and comply with their current fiduciary
obligations, Sun developed Fiduciary Boot Camp, a 1.5 day classroom training session,
stressing the need for fiduciary responsibility across the organization. Development and
presentation of Fiduciary Boot Camp was a joint effort by the Business Conduct Office, Sun Legal
and Sun Corporate Finance.
Attendees were educated in a variety of topics, including ethical leadership, compliance with U.S.
export control laws, current legal issues, internal audit and fraud prevention, anti-corruption and
bribery laws, and accounting policies and processes. Through this training, employees gained
awareness of fiduciary responsibilities shared by all Sun employees. In addition to enabling
participating employees to define their individual responsibilities for maintaining Sun's compliance
with the law, the Fiduciary Boot Camp also stressed the importance of using this knowledge
to promote a common understanding of Sun's responsibilities under the current ethical and legal
environment within their respective business organizations.
In 2003, 900 employees received this training via sessions presented in the U.S., Asia and Europe. Attendance was mandatory for all Sun Vice Presidents. In 2005, 1750 employees attended an additional ten sessions of Fiduciary Bootcamp held around the globe.
The content included in the 2005 series included key areas from the first Bootcamp but also focused on new subject matter, such as:
- Partner Management/Compliance
- Antitrust and Competition Law
- Data Protection and Privacy
- Insider Trading and Confidentiality
- Interactions with Media and Analysts
- Employment Law
Recognizing that not every Sun employee was able to attend a training session in person, a strong emphasis was placed on cascading the lessons learned. All attendees were required to deliver the key messages and learnings from the training to their individual organizations. To date, close to 1000 employees have accessed the Bootcamp materials online.
Business Conduct Online Module
Since July 2002, Sun's Business Conduct Office has been delivering mandatory, web-based business conduct training to all Sun employees. To date, approximately 35,000 employees, over 99% of Sun's employee population, have completed the online course.
Sun's web-based training is a comprehensive learning curriculum designed to assist employees in managing a variety of business conduct issues including for example, conflicts of interest, accepting and providing business courtesies, use of Sun's information systems and property, and fair competition. Because Sun employees are located throughout the world, the web-based training provides customized content by region and gives users the option of completing the module in Brazilian Portuguese, English, French, German, Japanese, Korean, Spanish, or Chinese (Simplified and Traditional).
Conflict of Interest Module
Sun's Business Conduct Office also offers training designed specifically to educate employees
regarding conflicts of interest including a conflicts of interest workshop and a web-based conflicts
of interest module. Geared for both intact workgroups and open enrollment, the classroom-based
workshop is designed to assist all employees in preventing and managing conflicts of interest when
conducting business on behalf of Sun. Specifically, the workshop provides employees with the
requisite knowledge to define what constitutes a conflict of interest, recognize a wide range of
potential conflicts of interests and identify and apply key elements of Sun's conflict of interest policy.
Both the workshop and the conflicts of interest web-based module have been developed and
implemented to support the mission of Sun's Business Conduct initiative and are based on Sun's
conflict of interest policy and conflict of interest-related questions.
Online Export Compliance Module
Under U.S. law, exporting is a privilege that can be suspended, revoked or denied. Jeopardizing Sun's privilege to export by failing to follow export control laws can result in substantial loss of Sun's revenue, severe fines, criminal penalties and damage to Sun's reputation. As part of Sun's ongoing commitment to ensure that all employees understand their export compliance obligations, a mandatory online learning module was introduced. The module takes approximately one hour to complete and was designed with several unique features including:
- Customized content by job function;
- Choice of Simplified and Traditional Chinese, Russian, Canadian French,
- French, Polish, Spanish and English languages;
- Automatic email notification sent to employees and their managers;
- Tracking and reporting capabilities; and
- Printable version for optional off-line study.
