You’ve probably heard the old joke/proverb, “How do you eat a bear? One bite at a time.” Whenever I hear it, it makes me think of compliance and ethics (C&E) training because effective training feels impossible (like eating a bear).
Let’s face it. Most online C&E training is boring. I’m a C&E consultant, and I have to force myself to sit through and pay attention to online modules. The graphics have gotten better, and the platforms are slicker, but we tend to offer online training not because we believe the training will change behavior but because it’s the most expedient way to track completion rates. It’s a way to check the box.
Checking the box is not a bad thing, and I don’t mean it in a purely pejorative way. If the Department of Justice or the Securities Exchange Commission or the state Attorney General comes knocking on your door for a C&E violation, it’s a benefit to the company to be able to say that it trained 99% of its employee base on important issues of C&E.
If we’re looking for training that teaches employees what our expectations are with respect to business conduct, though, and encourages them to ask questions and change behavior, there are more effective methods than online training modules. Videos are also helpful, but videos purchased from a vendor tend to lack a key element in achieving our goals, and that’s showing employees what C&E dilemmas and issues will look like for them on the job.
I spent a couple of years working with learning and development (L&D) executives in their constant search for training that makes a difference in employees’ effectiveness in role and has a positive impact on career paths. Unsurprisingly, online modules are ineffective generally, not just in the C&E space. What we found is that if you want to train employees on new skills, and you want the training to stick, it’s best to train people on the job.
What this meant in practice is that L&D needed to spend time with executives and managers not only determining what the company’s skill gaps were but also to spend time with executives and managers to identify the moments in an average day when learning opportunities presented themselves. This is a lot harder in terms of effort and time than offering videos and multiple choice and short-answer quizzes, but employees also learn more and faster and also retain what they’ve learned.
One of the best live-training decks I’ve ever seen was put together by the Chief Compliance Officer (CCO) of a global software company. A risk assessment and the CCO’s gut and experience showed that corruption was the company’s biggest risk and that Sales tended to be on the front lines of that risk. Instead of mandating that the sales executives take another module on anticorruption, the CCO sat down with a couple of those executives to get a clearer picture of what they do on a daily basis (a great example of listening and learning and creating an opportunity to code switch). Based on those conversations, the first page of the training deck was a page from an electronic calendar with all the usual meetings and calls and appointments most sales staff would see. The following pages gave a summary of what was planned for each of the meetings and calls and appointments along with the way that anticorruption and other risks would arise. The training was well-received, and the CCO and his team saw an increase in the questions coming in from Sales in the months following the training and opportunities to collaborate in solving problems early on, rather than being the “Department of ‘No.’”
Here are the steps and elements that made this training a success:
1) Risk assessment: spreading training like peanut butter evenly across the entire employee base only works if your company’s risk is spread evenly across the entire employee base. You won’t know for sure where the risk is without doing an assessment. (Confirming that your gut feeling was correct with a formal assessment should be a relief rather than a disappointment.)
2) Targeting: I’ve never had a conversation with a C&E department that didn’t know which employees were on the front lines of risk. Identify who those folks are and allocate training resources accordingly.
3) Listen and learn: it’s incumbent on us in C&E to do the work in figuring out how risk looks and presents itself for employees. They’re too busy trying to get work done and meet quarterly goals to meet us even 10% of the way.
4) Code switch: do the training in the target employees’ language from their perspective.
Online training is necessary for documentation, and I don’t advocate eliminating it. But we in C&E have the duty and obligation to supplement that training so that it’s meaningful and effective for employees. If we don’t, we risk our companies and their reputations – a high price to pay for not taking the first couple of bites of the bear.