Providing System Compliance Training to Accountants of a Global Pharmaceutical Company: The Switzerland Case

On July 30, 2002, President George W. Bush signed the Sarbanes-Oxley Act of 2002 (2002) into law. The legislation was crafted by the United States Congress to address issues related to accounting improprieties which came to light during the Enron scandal. The specific purpose of the legislation was "To protect investors by improving the accuracy and reliability of corporate disclosures made pursuant to the securities laws, and for other purposes" (116 Stat. 745). In order to comply with the law's requirements, financial officers of publicly-traded companies were now required to attest to the accuracy and validity of their companies' financial statements. The law stipulated that criminal charges could result from accounting improprieties. The passage of this legislation ushered in an era in which publicly traded companies began looking to implement systems and technologies that would help them comply with Sarbanes-Oxley (SOX) legislative requirements. This case study recounts the experience designing, developing, and facilitating a train-the-trainer software course for a global pharmaceutical company's Sarbanes-Oxley implementation. The paper will begin with an introduction of the case and a description of the stakeholders' roles. Secondly, the authors reflect upon the case through the framework of Caffarella's (2002) Interactive Model of Program Planning. Finally, the case concludes with details of the training program's delivery and a review of the case's implications on the practice of adult education. The names of the software company, the pharmaceutical company, and the audit firm discussed in this case have been changed to protect the identities of these organizations. Case Description and Stakeholder Roles Goriskco Software operates in the governance, risk and compliance market, with a focus on helping clients meet the compliance obligations of various industries by providing software for deploying online training and surveys, managing completion statistics for online courses, and managing company documentation. Following the passage of Sarbanes-Oxley legislation, Goriskco began marketing its software (Goriskco Enterprise) to customers looking for tools to support Sarbanes-Oxley compliance efforts. PharmaCo is a publicly traded multinational pharmaceutical company based in Europe. Since the company's stock is publicly traded on the New York Stock Exchange, PharmaCo is required to comply with Sarbanes-Oxley regulations. In 2003, Goriskco Enterprise was chosen by PharmaCo as the software tool to help manage PharmaCo's SOX compliance process. The Goriskco software implementation was part of a larger SOX compliance project, which included a comprehensive approach to meeting SOX mandates. The training portion of the project included a two-day train-the-trainer workshop for key PharmaCo finance personnel who would serve as the company's SOX trainers. The project team for the SOX workshop (see Figure 1) was led by a global audit firm, Smith & Company, LLP (SmithCo), which served as the expert on internal controls and SOX legislation. The information in Figure 1 is intended to review the internal and external factors impacting the case study's environment. However, the majority of this case focuses on the internal core of the project, which is comprised of interactions between the project team for the SOX workshop. External factors related to the legislative and regulatory environment are noted in the case, but are not a main focus of this paper, as it was not an aspect of the case which the project team members could control. [FIGURE 1 OMITTED] In the development of the software portion of the workshop, Goriskco personnel worked with a SmithCo training director who was responsible for the compilation and review of all program materials. The SOX workshop was conducted in Europe for 50 PharmaCo finance personnel representing eight countries throughout four continents. …