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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Sep 17, 2018

Over this series I am visiting with Peter Johns, Chief Marketing Officer, and Rebecca Turco, Vice President of Learning, both at SAI Global, the sponsor of this podcast series. In the series we are discussing the changes in ethics and compliance (E&C) learning and how a more technology-based learning solution can help move your company to a more effective and more operationalized best practices compliance program. In Part III, I speak with Rebecca Turco on the new SAI Global training solution at EthicsAnywhere.

EthicsAnywhere is SAI Global’s new training E&C solution. The solution began with an internal conversation at SAI Global and then moved to an extended conversation with their customer base. The idea that somewhere a new hire is spending their first day sitting through two hours of mandatory compliance training and one of their colleagues needs to complete a time sensitive course but they are traveling to meetings all week, and their manager is trying to figure out who has or has not finished their training yet, and a Chief Compliance Officer (CEO) is in the midst of planning their next launch of content without fully understanding how effective their previous efforts have been. How can you provide a training solution to meet these needs but meets the Department of Justice (DOJ) requirements that it be both effective and targeted?

For the new employee going through the compliance training, there is no context around it. You have managers who say, I need you to do the training and I need you to complete it because I am measured on that for my compensation. Yet in such a situation you might not be starting the training off on the right foot. One of the ideas behind EthicsAnywhere is that we live in a world where content is consumed and people make decisions if they agree with a piece of content or disagree within seven seconds of starting. If they are not engaged by that time, they will usually not pay attention anymore. EthicsAnywhere is designed to be engaging, literally grabbing the attention of the employee right out of the box.

Turco emphasized that we all know that millennials and centennials spend a lot of time on their phones, but the reality is that according to the Pew Research Center, every demographic of people in your company today spend more time online on their phones than their computers. So, when regulators ask if your training is in the ‘form appropriate for the intended audience’, we’d argue that a computer is no longer the appropriate form for the intended audience, and not offering training on mobile devices in the appropriate languages could actually pose a problem from an employee and regulatory perspective.”

This insight into the use of technology by millennials and centennials informed how the EthicsAnywhere compliance training solution should not only work but how its delivered. That delivery is as easy as opening up an application on their cell phone. This technological innovation removes barriers to compliance training and more fully engages the audience. Compliance programs have shifted to use better technology to make it easier for people to access content information which improves not only the effectiveness of the training but also the experience.

But there is a second innovative part to the EthicsAnywhere and that is the content. It is designed to “make sure that we have content that we can serve up to learners anywhere, literally anytime, whether they’re out on the road, in a sales meeting where they are accessing from it from their phone, if whether they are sitting in their workspace on their computer.”

The idea for EthicsAnywhere is to “provide meaningful solutions to our clients and our partners. This means relevant, meaningful content using all the delivery mechanisms of technology that exists today. The next step is to make this ethics and compliance learning program tailored and relevant for not only each company but also for each learner. For the learner, this means making sure that we are meeting them where they are and giving them what they need. It is being able to review your ethics and compliance training wherever you are and make it as simple as possible for you to get into an access information.” Turco explained that millennials and centennials  want to receive their training on their cell phones and they want it to look like any other piece of content that are looking at today. In short there should not be any entry barriers to receive the training.

One final thing about millennials which is extraordinarily positive, is that they seem to be very values driven and they are very focused on culture to drive the value base. They are very focused on a what companies do and what the reputation is in the workplace and in the marketplace. If a company has a misstep or makes a mistake, they expect a remedy. All of this tied into Turco’ final point about EthicsAnywhere, which is that it “is a modern approach to learning. It is responsive on any device, customizable for any organization, targeted to any user, available in any location, and translated in any language, so your employees can consume content at any time and prepare for any risk, and you can collect data to measure any goal your ethics and compliance program may have.”

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