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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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Dec 20, 2017

Welcome to the Day 3 of the five-day podcast series Jay Rosen and I are producing in honor of the latest Star Wars movie The Last Jedi. Each day over this week, Jay and I will review a Star Wars movie and discuss it from the compliance perspective. Today, we consider Episode VI, Return of the Jedi and effective training.

The full series schedule is:

Monday, December 18, Part I- IV-a New Hope and risk.

Tuesday, December 19, Part II- V-The Empire Strikes Back and due diligence.

Wednesday, December 20, Part III- VI-Return of the Jedi and effective training.

Thursday, December 21, Part IV- VII-The Force Awakens and disruptive innovation in compliance.

Friday, December 22, Part V-Rogue One and the myth of the rogue employee.

In this final movie from the original three, the good guys win in the end after overcoming incredible odds. Many fans and critics panned it for including the incredibly cute and furry Ewoks on the moon named Endor as a part of the storyline. Many thought one very tall Wookie was enough cuteness for the series. This movie’s big reveal was that Luke and Princess Leia were twins and that she was now free to unabashedly pursue bad boy Han Solo. While Episode VI was the lowest grossing film of the original three, coming in at only $572MM worldwide, it was still a great ride and visually stunning. George Lucas’ in-house organ, Industrial Light & Magic (ILM), certainly earned their title for their special effects in the movie. The Sarlacc battle sequence was great, the speeder bike chase on the Endor moon was way cool and the space battle between Rebel and Imperial pilots was a great ride.

I have adapted an approach from Joel Smith on his Inhouse Owl website to help determine compliance training effectiveness.

1.What you want to measure. Before you ever train an employee, you should have a goal in mind. What actions do you want employees to take? What risks do you want them to avoid? In compliance, you want them to avoid non-ethical and non-compliant actions that would lead to compliance violations. The goal is to train employees to follow your Code of Conduct and your compliance program policies and procedures so you avoid liability related to actions.

2. What is employee engagement? The next step is to get a sense of whether employees feel that the training you provided is relevant and targeted to their job. If it’s not targeted, employees will likely not be committed to changing risky behavior. You can get data on employee engagement through a quick post-training survey, which will help you isolate and qualify the training benefit.

3. Did employees actually learn anything? A critical part of any employee training is the assessment. If you want to understand the “benefit” of training employees, you must know whether they actually learned anything during training. You can collect this data in a number of ways, but for compliance training, the best way is to measure pre-and post-training understanding over time. Basically, each time you train an employee, measure comprehension both before and after training.

4. Are employees applying your training? You need to conduct a survey to determine employee application and their implementation of the training topics. To do so, you must conduct employee surveys to understand whether they ceased engaging in certain risky behaviors or better yet understand how to conduct themselves in certain risky situations. These surveys can provide a good sense of whether the training has been effective. 

Join us tomorrow where we consider The Force Awakens and disruptive innovation in compliance.

May the podcast be with you this holiday season.

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