CCO Insights

In-Person Training as Good Use of the Compliance Expense Dollar

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I was calling my wife from the West Coast—heading home to DC after four days of in-person company Code of Conduct training in a Pacific island location, preceded by 10 days of training elsewhere. But as I was giving her my arrival information, a compliance colleague started waving his cell phone and pointing west. A few hours later we found ourselves flying back to the island, responding to an anonymous call to the company’s “hotline,” to investigate allegations of potentially serious inappropriate employee conduct.

The timing was not a coincidence. At the conclusion of each training session—whatever the location—we would spend a few minutes asking participants to contact us if they had any concerns and detailing the various ways they could do so. The last slide of the presentation contained this contact information, and we always left it up on the screen for full impact as we met with employees during the receptions that followed these sessions.

In this case, one of the island training gatherings resulted in that call to the hotline: the caller said that they had lingering concerns about certain employee behaviors, and the recent training session had provided the information and impetus for making the call.

A team of four of us spent the next week investigating the allegations in detail. As is often the case, the facts offered by the hotline caller had been provided in good faith but told only part of the actual story. Upon investigation, the complete facts did not support the allegations, and the “suspicious” behavior at issue was both understandable and innocent. (On the other hand, my wife was not convinced that my need to go back to the sunny island was entirely “innocent.”)

But even putting aside the favorable result of the investigation, this series of events resulted in several “wins” for the company:

  1. The process worked: the information was received, and employees had sufficient trust in the compliance process (including the people involved) to contact the hotline to share the issues of concern internally.
  2. Compliance acted promptly, and this was noticed. The “corporate grapevine” is a truly efficient means of communication, and the fact that this matter was handled quickly and professionally instantly became company-wide knowledge. This event became part of the culture of a company previously influenced by essentially entrepreneurial themes—and this changed culture was recognized as an asset when the company was subsequently acquired.
  3. The investigations process had limited costs and involved minimal disruptions to company operations. This is relative, of course, but consider the alternative: had the caller chosen to contact the SEC or other applicable federal agencies, the resulting costs and consequences would have been considerably greater—to likely achieve the same result.

For general counsel and chief compliance officers at companies that operate on a calendar year basis, it is now time to plan and budget for next year. As you go through this process, consider the various ways that value is added by being on the ground to conduct training at company locations away from your home office. In-person training visits involve more than the transmission of information to employees—online training can accomplish this. But in person visits also allow compliance personnel to listen, to form relationships, and to add the human element that may encourage someone to come forward with information you and your company need to know.

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