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Over the past few weeks, we have discussed a number of factors companies should consider when developing a compliance training plan: targeting the right audience, training at appropriate intervals, addressing the important topics, and engaging while educating. In this final post in the series, we discuss who should actually conduct this training. The following are possibilities:
Involving compliance personnel in the training program serves a few important functions. First, because compliance personnel are – as their title indicates – compliance experts, it helps ensure that the training is accurate and hits the right topics. Involving compliance personnel also allows for the two-way communication between the functional and field personnel that is essential to an effective and operations-oriented compliance program. Compliance personnel learn directly from local personnel what risks they regularly encounter and what questions they have about the way the compliance program should operate. Local personnel get to know compliance personnel, which will hopefully lead to less hesitation on their part when they have questions or concerns that need to be raised.
The ability of compliance personnel to participate in all training sessions depends in part on the practicalities of time and resources. Some companies have multiple compliance personnel who can be tasked with traveling to local offices to present training. In companies where the compliance function resides with only one or a few individuals, some degree of delegation may be necessary. One option is for the chief compliance officer to engage in “train the trainer” sessions to enable other personnel (such as local managers) to knowledgeably present. Another option is for the chief compliance officer or other compliance personnel to engage in video-conferencing with local offices as part of local training, so that local personnel still have some opportunity to become acquainted with the compliance function at headquarters.
Even when the compliance function does not participate in all training, it is critical that group members make themselves aware of how training is going and being received. “Dropping in” at local offices and engaging in informal discussions with employees is one way to do this.
Management, including local managers
Management involvement in training is one way to support tone from the top. As we discussed in our last post, having the CEO and/or other senior leaders as key compliance theme communicators helps demonstrate the company’s commitment to compliance. Having local managers participate in training serves other important functions (assuming the local managers are viewed as credible individuals who act consistently with their messages). When local personnel see that their bosses understand and care about compliance, they are more likely to comply. They are also more likely to turn to their local managers when they have compliance questions or concerns.
Outside consultants can be a valuable resource in preparing and presenting compliance training. Consultants may have special expertise about a compliance issue as well as the resources to make training sessions more entertaining. For example, they are often able to share current trends, case insights, lesser-known facts about compliance, and “war stories.” They also may lend a degree of authority to the training. Furthermore, headquarters personnel may “perk up” a bit more if the instructor is not a person they see every day.
The training function should not be fully outsourced, however. If compliance personnel are not involved in training, the company will miss an important opportunity to listen and learn about the risks employees face on the ground and to receive program feedback. Employees will similarly miss the opportunity to spend time with those colleagues tasked with preventing and detecting compliance issues – to better understand their roles and responsibilities.