Corruption risks take a variety of forms, from expensive gifts and entertainment to politically-connected suppliers and facilitation payments. While the same rules may apply to everyone in the company, they affect each role differently. For example, salespeople are likely to face different compliance challenges than those on the finance team, and require different training. But people tend to overlook the need for specialized training for executives and middle managers, with messaging that emphasizes the strategic business value of an effective compliance program.
WHY DO EXECUTIVES NEED TARGETED TRAINING?
Let’s say a salesperson submits an expense report that includes tickets to a Broadway show and receipts for a couple of fancy dinners. The finance team may automatically flag these expenses for investigation, since most employees are subject to certain pre-approval rules. An executive could submit the same report, however, and not be automatically flagged. As a result, they may be less aware of the rules surrounding such purchases.
Effective training starts with messaging that is appropriate and relevant to a specific job, role or function. In general, executives are viewing the business from more of a strategic perspective; as a result, they should receive a broad, higher level understanding of how anti-corruption and compliance can be used to create and capture value.
Too often, people think of compliance activities in terms of fear; as things that must be done to avoid costly settlements or criminal penalties. True, it’s important to remember that executives and other senior-level people can face individual civil and criminal liabilities for anti-corruption violations. However, a better approach for training executives is to emphasize how compliance programs demonstrate business savvy and a commitment to ethical behavior on the part of the company and its leadership.
Demand From Customers And Potential Partners
In this day and age, people won’t want to do business with you unless you have a good compliance program in place. Many prospective partners will ask to audit or vett your program as a condition for a joint venture, for instance. If you don’t have a documented anti-corruption compliance management program, you’re likely to to miss out on partnership opportunities.
Managing Risk In A Strict Legal And Regulatory Context
If you get a knock on the door from external audits or from an enforcement agency, you want to know you can answer their questions about compliance training. If a company is being investigated by authorities, they have a far better position if they can demonstrate that adequate procedures controls were in place. The DOJ, for instance, recently released an evaluation guidance of what it perceives as important constituents of a corporate compliance program, in which it emphasized the importance of management and senior staff’s “shared commitment” in promoting compliance.
While these evaluations do not provide a one-size-fits-all solution, executives should be reminded of the value of demonstrating a strong compliance program. “Tone from the top” may sound a bit fuzzy, for example, but you never see a scenario where there’s really great training and buy-in at the top that just doesn’t flow down and permeate the company. You could still have a rogue actor or bad apple, but your chances are better that someone is going to raise awareness if the overall culture is supported at the top level.
TECHNOLOGY FOR TARGETED TRAINING
One of the challenges of providing training that’s tailored to executives is the complexity that comes with managing multiple tracks. The technology that has typically been used in compliance further compounds this challenge. In the past, companies have used separate tools to manage compliance activities. The result is added complexity and data silos. Fortunately, today’s technology solutions can bring compliance activities and content together to provide training that is tailored to job functions.
In the end, providing focused, job-specific training is a must for your compliance program, whether you’re talking about an executive or a mid-level manager, a salesperson or finance officer.