Jeffrey M. Kaplan

The material, available as online videos, is designed to "have a long mental shelf life," said Jeffrey M. Kaplan, a Midi vice president."Nobody ever asks an employee to commit a crime three days after training," he says."The devil on your shoulder is always pretty big: your boss or a customer in your face.The question is, what is your little angel going to say?We want our training to give the devil a run for his money."Kaplan says what's driving the ethics boom is not so much the SOX legislation, as the increased tendency of prosecutors and regulators to take ethics programs into account when considering charges.Midi also sees demand for training on the Foreign Corrupt Practices Act, antitrust issues, and harassment.

One Sarbanes-related script Midi produced depicts a sales executive persuading a customer to help inflate sales numbers by accepting goods that can be returned later.The sales person, in turn, asks another employee to help cover up the arrangement.The second employee considers reporting the problem, but doesn't, lies to an FBI agent, threatens a whistleblower, and eventually goes to prison - a chain of events "you're likely to remember for a long time," Kaplan says.

Brown explains that the opportunity to work with Midi stemmed from his collaborative volunteer work with Jeffrey Kaplan, Midi's vice president for law, ethics and compliance, who is active with Brown in the Ethics & Compliance Officers Association.
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Jeffrey Kaplan

"What the Stonecipher case does is help companies view 'company business' perhaps more broadly and policy violations more broadly," said Jeffrey M. Kaplan, an attorney and member of the Law and Business Ethics Advisory Board at Midi Corp., which develops compliance and ethics training programs.