(Want to get articles like this one by email? Here is the sign-up!)
Our last post highlighted basic areas you may want to target in a compliance training program. This post discusses the related question of how to present this material. The outcome you hope to achieve should inform the process you use to teach about compliance. Accordingly, begin by asking yourself the following questions: What is the goal of this training program? What skills and/or impressions do we want personnel to have as a result of this training? If audience members leave with just one “take-away,” what would we want that to be?
For example, in the area of anti-corruption compliance, “training provides the knowledge and skills needed to employ the organisation’s procedures and deal with any bribery related problems or issues that may arise” (The Bribery Act 2010, Guidance about Procedures, p.29). After personnel complete a compliance training program, they should understand their obligations under the law and under the compliance program and be able to recognize and respond to those compliance risks most likely to occur. If the training is sufficiently persuasive, employees will also be motivated to comply with your company’s compliance program.
Each of these training goals – understanding obligations, issue recognition, and actually following the program – lends itself to different means of engaging employees. Consider the following possibilities:
Helping personnel understand their obligations
Traditional in-person or online training is the primary way that individuals learn about the laws, policies, procedures, and controls that apply to them because of their company role. But some individuals are overwhelmed by, or are non-receptive to, the number of “rules” that some training contains. Quizzes, games, videos, and other recall activities can help personnel commit key points to memory in a less obtrusive way.
Personnel also need to recognize the serious consequences of noncompliance. Incorporating factual case studies into training can highlight the potential consequences of breaking the law. The best examples are government investigations or prosecutions that occurred in your industry, are notorious, and/or involved wrongful conduct of the type you are trying to avoid.
Periodic brief reminders by way of a “vignette” (for example, a humorous film clip) included in emails can reinforce key compliance themes in a positive way. Providing such reminders also has ancillary benefits for the compliance function: employees notice that serious topics are dealt with briefly and creatively, and appreciate that compliance personnel show a “human side” sense of humor, rather than following more traditional (and drier) training approaches.
Helping personnel develop the skills to recognize and respond to compliance risks
Simply lecturing about potential risks does little to engage personnel. Since “practice makes perfect,” give personnel an opportunity to identify and respond to potential risks your company might actually face. For example, have trainers present examples of various “everyday” circumstances personnel might encounter in their jobs. Interactively engage the audience (using a “light Socratic method,” perhaps) to identify what about these situations creates compliance risk. Then, have trainers lead a discussion of the various ways to respond appropriately to these risks. Role-playing activities are helpful in this regard (and are often perceived as fun by participants). Having smaller groups helps provide everyone with a chance to practice (not just those who are more outgoing).
Motivating personnel to comply
Generally, training presents opportunities to motivate your personnel to be more conscious of, and proactive about, compliance. Trainers can also use this time to convey a specific message that, in the authors’ experience, can have a disproportionately positive effect. Begin the training session by introducing yourself to the group, and then state, “My job is to facilitate sales.” (The reactions of an audience to this statement by a compliance person are fascinating, by the way, and can range from total surprise and silence, to laughter, to smiles that suggest listeners are gaining an entirely new perspective.) Follow up with an explanation that you, like other employees, perform a certain role associated with supporting company goals, and that your particular role is designed to drive good business. Then, make an offer to spend time with any employee encountering a particular internal sales obstacle (whether compliance-related or not) to help find a way to make the sale. Finally, after the session, put your words into action. This approach produces immeasurable good will and introduces an entirely different dynamic into the corporate grapevine compliance discussion.
Outside speakers can help get employees’ attention by sharing “war stories.” Your own colleagues can be impactful, as well. By sharing their vision of what compliance means to the company (and assuming that their past word and deeds are consistent with that vision), your CEO and/or other senior leaders can help build the tone from the top that is essential to any compliance program. Moreover, including them in training (preferably in-person, but alternatively by pre-recorded video) helps demonstrate the weight your company places on compliance.
A strong suggestion: do an informal litmus test on proposed internal speakers. Go to colleagues whom you trust and bounce possible names off them. If any reaction to a speaker candidate is less than positive, consider other alternatives. Although a strong internal speaker helps support a compliance program, there is no quicker way to severely damage a program (and the chief compliance officer’s standing) than to feature an internal speaker at an event who is viewed as lacking credibility or sincerity.