Over this podcast series I visit 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 discuss 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 II, I visit with Rebecca Turco on the shifting compliance mindset.
One of the most interesting things about the E&C marketplace is that all parties involved contribute to this evolution. From the regulators or prosecutors to companies and their compliance personnel and programs, to product and service providers in the marketplace. Everyone has contributed to this evolution and will continue to do so going forward. Turco noted that it has evolved far beyond “providing compliance content and checking the box”. It is significant that compliance is now part of the culture of a company. “The trends that we’re seeing really around how our company’s embedd compliance and culture in their organization.”
Turco said that compliance training now is around changing employee behavior. This has led to consideration of the effectiveness of training and analytics around it. Turco has seen a “shift from 30 to 40 minutes of training to targeted training and targeted pieces of content. Companies want to be able to make sure their employees are valued in terms of the time they are spending on compliance training.” They not only want to measure compliance training effectiveness to show that the program is working but also to show risk areas that could present an issue(s) for companies going forward and warrant greater attention.
The targeted nature of training means tying training to the overall business process. So how does your compliance training help an employee do business more efficiently and, at the end of the day, more profitably? Are both goals appended onto and embedded into compliance training? This is one of the goals the Department of Justice (DOJ) included in its requirements for effective compliance training. It is getting away from death by a PowerPoint slide deck or Xerox copy to have compliance training which is much more engaging. Indeed, companies want more focused and targeted training for the risk that people are engaging in and the risks people have out in the real world.
It is interesting to observe the spectrum of the players in the compliance space and how each player has a specific role in driving compliance forward. The DOJ began the dialogue about effectiveness of compliance training in the General Cable Technologies Corporation Foreign Corrupt Practices Act (FCPA) enforcement action. The DOJ then added the mandate for targeted training in its Evaluation of Corporate Compliance Programs (Evaluation) in 2017. That was really the first time they had said in a policy statement that they wanted to see not only that you have effective training but targeted training as well.
I asked Turco how, as a learning professional, a company can begin to measure compliance training effectiveness? Turco said, “the key to any learning objective is being able to understand its concepts and understand how it applies to you and then it’s daily, weekly or monthly repetition. It’s not a one and done.” This means that when thinking about compliance training effectiveness you should “begin with a high-level offering that talks about kind of risks in the business. The next step is to have the learner understand what it means to them.” Effectiveness most probably will not occur the first time they take the course. Turco was emphatic that it is not “a one and done.”
Real world working environments are complex. This leads to training which impacts learners in a way that allows them “to understand what the risk is, they need to understand what to do if presented with that risk, where to go, how to report if necessary, and then they also, over time, need to understand how that risk presents itself in their job.” This means you must consider effectiveness and you have to follow up with some type of reminder about that training. Such continued training could occur through infusion in conversations with middle managers, messages from your company’s Chief Executive Officer (CEO). Such continued messaging helps to create a culture of compliance within your organization and re-emphasize that “compliance is not a one stop event.”
Turco then tied the targeted concept to this effectiveness component. She said that in providing scenarios of business risk and how employees react or respond, you begin to build a database of analytics and information. With this data you can start “to measure where people are, where people really feel what they think, what they understand.” This data can give you a roadmap to begin to drive your compliance program year after year. You can take the data so you will better understand where your learners are and then help them along that journey.” Obviously, this means that not everyone gets the same training. “It means that we are going to make sure that we’re helping you teach that employee what they need to know, understand how those risks present themselves. And then continue to train and remind them of how that may come up and in their daily job in life. So it’s a measurement over time with effective questioning and targeted content.”
The role of compliance training continues to evolve. The regulators, in the form of the DOJ, have articulated a requirement for both effective and targeted training. Companies have responded by seeking ways to help their employees more effectively identify and then manage risks. But it is not a one-time event or one-way street. Effective compliance training is a continuing dialogue which allows organizations build their reputational brands.