From the Field – The Edison K-8 School, Boston, MA

Over Boston Public School’s February vacation week, 24, 3rd & 4th grade Edison students were working hard to “sharpen the saw” using Vault through First Republic Bank’s sponsorship. Although it was a short 4-day week, the students were able to login and work on the modules while they were in school, something they looked forward to doing before going home each day. On the last day of vacation, First Republic representative Heather Lombardo and Rhyshonda Singletary visited the class with me to honor their hard work and celebrate the students success with Vault. Although only 5 students actually became certified, the rest of the class was just one or two modules away. The class was so excited to show us what they learned through a fun game of Jeopardy that we played with Vault questions. Each students was able to leave February vacation’s “Acceleration Academy” week with a First Republic piggy bank, and some even with a certificate.

School Manager: Maraget Bane
Teacher: Jarod Johnson
School:The Edison K-8 School, Boston Public Schools
City: Boston, MA
Course: Vault

From the Field – H.M. King High School, Kingsville, TX

Ms. Carrillo’s seniors have been using the EverFi course this year and we had the pleasure of bringing in a member of 1st Community Bank of Corpus Christi to host a certification ceremony with the students. Beyond receiving the certificates, the students dominated financial literacy Jeopardy and shared incredibly thoughtful reflections and posed meaningful questions about their own financial wellness and future. It was so amazing to hear the students’ reflections and to hear from Ms. Carrillo about the impact the course has had on this group of students as well as her past classes who have since graduated.

School Managers: Dakota Rubin & Heather Witcher
Teacher: Diana Carrillo
School: H.M. King High School in Kingsville ISD
City: Kingsville, TX
Course: EverFi

Interview with Harriet Sanford, President & CEO of the NEA Foundation

We recently sat down with Harriet Sanford to hear about her impressive 40-year career in education, and her current work supporting public teachers and students through the NEA Foundation. The interview has been edited and condensed for clarity.

Harriet Sanford

Why did you go into education? 

I began my career – 40 years ago (sigh!) — as a public school teacher at Arbor Hill Elementary School, in Albany, NY, just blocks away from where I spent the first seven years of my life. Although I did not remain in the classroom for many years, my commitment to improving lives and underserved communities for the better never faltered. It has been a privilege to work in education philanthropy for the last 12 years, but make no mistake, it is educators who go to work in the trenches every day, not funders.

Neither my mother nor father completed their educations. Nonetheless, they were adamant that their children take advantage of all of the opportunities that a public education offers — both in and out of school time. They fully expected their children to pursue higher education and ensured that we could immerse ourselves in our studies, service, sports, and more. With many communities, schools and families just like mine facing insufficient resources, my work and the Foundation’s work is to do all that we can to ensure that every student has access to a high-quality education and finds his or her own joy in learning.

What is the NEA Foundation and what support does it give teachers?
The NEA Foundation is an independent, 501(C)3 public charity, created, in 1969 by educators for educators, to improve public education for all students. Highlights of support for teachers include:

  • Our Grants to Educators, distributed three times each year, fund educators’ creative and innovative classroom projects designed to prepare students for college, work, and life. Last year, our grants empowered more than 6,000 educators, reaching more than 186,000 students.
  • Our annual Awards for Teaching Excellence honor the challenging but crucial work that public school educators do every day. We reward outstanding educators who are shining examples of the millions of people who work tirelessly in America’s public schools, in service of students, but seldom hear how much we appreciate them.
  • Our Global Learning Fellowship, takes a group of educators abroad, such as on recent trip along the Inca Trail to Machu Picchu and other significant historical and cultural sites in Peru, as part of a year-long, cohort-based, professional development program. Participating educators return from their travels with fresh knowledge, skills and perspective needed to teach in the global age, and better equipped to deliver globally focused curriculum in their home schools and communities. Fellows also contribute to a growing, freely accessible, online collection of 195 lesson plans, accessed by peer teachers around the country more than 4,000 times.
  • We regularly produce issue briefs sharing the Foundation’s and our partners’ lessons learned on a wide range of topics and disseminating actionable information that helps educators overcome challenges to teaching and learning.

How do EverFi & the NEA Foundation work together?

The NEA Foundation and EverFi work together to increase educator and student access to technology and digital learning tools. We collectively strive to support critical skill areas that will enhance students’ ultimate academic and life success.

The partnerships currently supports NEA school districts across the country, providing free access to EverFi’s digital resources and accompanying professional development. Districts that have participated include Springfield, MA; Lee County, FL; and Prince George’s County, MD. Our partnership is leading us to work on more programming in STEM and to develop initiatives in social and emotional learning.

What encouragement would you give teachers who are working to integrate critical skills education into their classrooms?

My key piece of advice to educators, no matter what or whom they teach, is almost always the same: It takes “fierce” to battle your own self-doubt when you are the only one who seems to know that “good enough” is just not good enough for your students. Excellence is what you are after, and you are not going to let anything or anyone stand between your students and excellence. Bring “fierce” to the table every time. Be gentle, kind and caring with your students, but be fierce about their education.


Thanks to Harriet for giving us a glimpse into the important work she and the Foundation are doing to support public school education! If you’re interested in learning more about EverFi or our work with the NEA Foundation, reach out to Steve Sandak at

Marketing to Millennials: What Not to Do

As the millennial generation ages into more prominent jobs and accumulates greater wealth, banks and credit unions are quickly realizing they need to improve their financial marketing strategy to attract this elusive demographic. But despite the fact that this generation seems to be online at all times, it takes more than a fancy website to make a connection. While many financial institutions have been online for years, attracting millennials requires a full understanding of this demographic to drive impact.

Millennials learn and bank differently than previous generations. Learn how your financial institution can attract this elusive demographic.

Millennials learn and bank differently than previous generations. Learn how your financial institution can attract this elusive demographic.

Here are two of the most common financial marketing mistakes that banks and credit unions make targeting millennials:

  • Neglecting Mobile

Always on-the-go, millennials today are more likely to be surfing the Web on a device than they are on a computer. Yet many financial institutions still neglect to ensure that their websites and marketing materials are optimized for mobile devices. When designing anything that will live online, from website menus to online programs, ensure that your designs are compatible with mobile devices of all sizes—and will work in different browser types (including Chrome, Safari, Firefox, and IE). Better yet, consider designing for mobile from the start.

  • Overly Long or Text-based Content

Millennials are fast-moving multitaskers. They want to maximize the “downtime” in the cracks and crevices as they move through their daily life: sitting on the metro, waiting for a friend at a bar, or even in the final moments before drifting off to sleep. Help them do that my creating content that is short and to-the-point. For best results, consider infographics, videos, and short, crisp articles that relay maximum information.

How To Improve Your Millennial Marketing Strategy

Banks and credit unions that want to connect with the millennial generation would be wise to meet them where they are—which, today, is online as they’re out and about. But it has to be done right. For more tips on how to avoid marketing pitfalls, check out our mini-guide


How to Measure Compliance Program Effectiveness

Having an ethics and compliance program with no implementation plan is akin to implementing the program without measuring its effectiveness. There are plenty of resources expended but no one is sure what, if anything, is gained. This post continues our discussion of ethics and compliance programs, which has covered the hallmarks of a compliant program, tone at the top, hotlines, and now we’ll address how to measure the fruits of those efforts.

DOJ Guidelines: “Evaluation of Corporate Compliance Programs”

The Fraud Section of the U.S. Department of Justice (DOJ) has indicated that its Foreign Corrupt Practices Act (FCPA) enforcement efforts will remain unchanged under the new administration. In the month after the inauguration, the DOJ’s Fraud Section issued the “Evaluation of Corporate Compliance Programs” (ECCP), a litany of “important topics and sample questions” to help companies evaluate their compliance programs. In addition, Trevor McFadden, the deputy assistant attorney general now overseeing the Fraud Section, gave a speech in which he reportedly said that FCPA enforcement and prosecution of individuals will continue to be priorities, and compliance efforts and cooperation with investigators will continue to be rewarded.

The ECCP provides a blueprint for internal reviews of compliance programs by asking questions to determine if a program is working. And if it’s not working, to determine what needs to be fixed. Hui Chen, the Fraud Section’s compliance counsel, is given credit for drafting the recent guidelines, which rely heavily on the “Filip Factors” that DOJ prosecutors use to guide their criminal investigations of corporate entities. The questions are aimed at gathering specific information about how a company implements its code of ethics or other corporate compliance program, and what steps are taken to measure its success or examine the root causes of violations.

The ECCP’s 119 questions drill down to find answers to the three basic questions we have written about before, that guide how the DOJ/SEC evaluates ethics and compliance programs, as set forth in their FCPA Resource Guide:

  • Is the company’s compliance program well designed?
  • Is it applied in good faith?
  • Does it work?

.Data Metrics: The “Hidden Gem”

The ECCP guidelines identify what companies need to ask themselves about their compliance programs, but they don’t tell companies how to go about getting the answers. As with many business operations issues, the answers are found in the data. In fact, data is called the “hidden gem” that provides a factual basis for measuring and assessing the effectiveness of ethics and compliance programs.

And the FCPA Blog says, “Data lies at the core of the [DOJ] guidance.” The author provides these examples of “compelling metrics” that reveal a program’s effectiveness:

  • How many transactions or deals were subjected to greater scrutiny because of compliance concerns?
  • Have requests for resources for compliance and control functions been denied?
  • How many internal audits have been performed in response to transactions that bore signs of bribery and corruption?
  • Where misconduct was identified, was there an investigation to find its root cause?
  • Were third parties or acquisition targets evaluated or audited for compliance issues?

This brings us to the next question: where do you find this information? Conducting employee climate surveys can help identify program strengths and weaknesses. If surveys are conducted at regular intervals they can also provide benchmarking data. For example, the data can help identify trends and determine if changes to compliance functions and controls have resulted in increased effectiveness.

In a presentation, “Ethical Culture: Defined and Measured,” the results of a company’s culture (essentially broader than climate) survey were used to compare the perceptions of its non-supervisory employees with those of its managers and executives, providing valuable insight into whether perceptions about the company’s ethics and culture are aligned throughout the company.

Data Triangulation: Test the Validity of Information

However, using one source of information may leave out important data points or allow bias to skew the data. Data triangulation involves using multiple data sources to test the validity of information. For example, other sources of information besides culture or climate surveys may include internal audit, or hotline and training data that verify or challenge the survey findings.

Under the U.S. Federal Sentencing Guidelines, one of the factors that mitigates the ultimate punishment of an organization is the existence of an effective compliance and ethics program. The DOJ/Securities and Exchange Commission (SEC) FCPA Resource Guide reinforces the need for risk-based compliance programs and an appropriate evaluation of them for continuous improvement and sustainability. For example:

  • Hotline use, response to reports, and outcomes
  • Progress of any new initiatives or compliance program enhancements
  • Training frequency and completion rates
  • Culture survey results.

Among other things, conducting culture surveys reveals how employees perceive their workplace environment and if they believe individuals at all levels of the organization are held accountable for misconduct. Additionally, surveys can measure the strength of internal controls, identify best practices, and detect new risk areas.

Research has found that culture, leadership, and values-based ethics and compliance programs increase employee reporting of misconduct and decrease retaliation. To address these issues, a list of recommended metrics includes:

  • Reviewing and updating ethics and compliance programs
  • Conducting culture surveys and knowledge assessments
  • Measuring training program reach, medium, frequency, and completion rates
  • Tracking reporting and retaliation trends by location, department, or employee
  • Identifying emerging risks through enterprise-wide risk assessments.

Make Informed Decisions Based on Data

Besides helping to create an effective compliance program, data forms the factual basis for making decisions about where resources can have the most impact. Making decisions about resource allocation based on verifiable data can move the dial from response and remediation to prevention by detecting potential problems before they happen, thereby creating a compliance program that is an effective prevention tool.

Data provides impact by measuring both the effectiveness and compliance of corporate ethics programs, and by assessing programs for outcomes and identifying problem areas such as:

  • Is the program being properly implemented?
  • Are the company’s values and ethics modeled by senior and middle management?
  • Are there sufficient control functions to detect misconduct?
  • Is there a shared commitment to ethical conduct among the company’s different components?
  • Do the company’s values and ethics play a role in making strategic and operational decisions?
  • Is there sufficient autonomy, empowerment, funding, and resources provided to the compliance function?.

As we’ve written before, “good ethics are about making good decisions, and good decisions are good for business.”

Continuously Measure Your Compliance Program 

Whether it is improving procedures to fill gaps or gathering information to perform risk assessments, data plays an important role in preventing misconduct and demonstrating a company’s commitment to effective ethics and compliance programming. Above all, data informs decision-making and provides ROI in more ways than the bottom line.

Surveying employees, conducting focus groups, analyzing existing data sources, and continuously tracking these metrics over time is a critical part of an effective ethics and compliance program.

LawRoom (powered by EverFi) delivers online training to help your business meet compliance requirements both dynamically and scalably. In addition to our award-winning online courses, LawRoom delivers a robust, cloud-based learning management system to help you easily deploy and track our growing library of ethics, anti-harassment, data security and employee conduct courses.