4 Takeaways for Compliance Officers in 2022
A couple of years ago, someone named Jared posted what he called “The Shopping Cart Theory” on Twitter and it exploded on social media. Jared proposed that we can assess a person’s moral character – essentially whether they are capable of self-governing or not – based on whether they return their shopping cart.
“To return the shopping cart is an easy, convenient task and one which we all recognize as the correct, appropriate thing to do. To return the shopping cart is objectively right. There are no situations other than dire emergencies in which a person is not able to return their cart. Simultaneously, it is not illegal to abandon your shopping cart. Therefore the shopping cart presents itself as the apex example of whether a person will do what is right without being forced to do it. No one will punish you for not returning the shopping cart, no one will fine you or kill you for not returning the shopping cart, you gain nothing by returning the shopping cart. You must return the shopping cart out of the goodness of your own heart. You must return the shopping cart because it is the right thing to do. Because it is correct.”
Even the New York Times weighed in on shopping carts.
And while I wouldn’t go so far as to say that returning your shopping cart makes you a moral person or not, there are some interesting parallels we can make with respect to compliance.
- Will people take the correct actions when there is no law prohibiting it, or no one watching?
- Are there factors other than legality or mortality that motivate people to do the right thing?
- How does human behavior, emotion, experience, etc. play into one’s decision about the about the action they choose to take?
The best indicator of whether a person will do the right thing is when the person does the right thing. But what’s right for some may not be right for others. This is exactly why companies must tell their employees what is right, what is wrong, and what is expected of them. At Skillsoft, we see many of our customers doing this through their compliance training program and code of conduct.
Skillsoft is grateful to have worked with some amazing clients in 2022, many of whom have established effective online compliance training programs and, dare we say it, successfully gotten their employees to return the shopping cart.
Here’s what we learned from them this year!
Train Your Team “In the Flow of Work”
In 2022, organizations increasingly saw learning take place when – and where – learners need key information. Lynn Ross, senior director global operations training and development at Equinix, shared her thoughts on this topic as part of a webinar on building a successful global safety program, and she hit the nail on the head.
Imagine you are about to go on a bike ride and your chain falls off. Maybe you have a general idea how to fix it, but you can’t remember the details. But you are all dressed in your gear and you’re planning to leave soon, so you need access to the information you’re looking for as soon as possible.
You probably wouldn’t sign up for an in-person course on bike maintenance. Or take time out of your day to engage in a 45-minute training session with a quiz at the end. Instead, it would likely be most useful to you to watch a two-minute YouTube video showing you how to fix the chain.
Not only would you get the information you need when you need it, but you would learn what you need to know by seeing and hearing it. Chances are, you’ll be able to recall that information more accurately later because you were able to learn it in the flow of work – when you needed it.
Compliance professionals who want to truly impact employees and mitigate risk understand that these learners need information at their fingertips. This requires an investment in multi-modal training courses that can be utilized when needed—just in time.
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Remove Training Silos
There is a logic to compliance silos. The IT or Security team handles cybersecurity because they have the requisite expertise. By the same token, IT likely doesn't know much about bloodborne pathogen safety — that's a job for the environmental, health, and safety (EHS) experts. Anti-bribery and corruption, that for sure lies in the expertise of the Compliance or Legal team.
The problem is that silos often prevent collaboration, leaving an organization unable to assess risk holistically. Under a more collaborative approach to compliance, disparate teams could more easily share information and insights, ensuring that every segment of the organization takes the necessary precautions to protect employees and the company. In turn, that can help the organization see and mitigate compliance risks faster — before they snowball out of control.
Global packaging leader TricorBraun has been partnering with Skillsoft to centralize its legal compliance solution for some time. However, the organization’s overall program was still decentralized with various managers owning different aspects of compliance training. To combat inefficiency, Director of L&D Kary Gilkeson and L&D Specialist Sarah Rinne completed a compliance audit with the goal of consolidating compliance training across the board.
Gilkeson and Rinne started with cybersecurity, a critical component of any modern compliance program. “TricorBraun used to issue cybersecurity training through a different system, as cyber compliance fell under IT,” said Gilkeson. “When we moved the training to Skillsoft, ultimately reaching 1,400 to 1,500 people across global regions, we started realizing the benefits of compliance across the board.”
The non-siloed, Skillsoft compliance training was able to boost confidence and awareness for team members that previously worked without critical risk-mitigating insights.
Incorporate ESG into Compliance Training Initiatives
Many companies have only recently established Corporate Social Responsibility (CSR) programs, yet they now face expectations to have measurable Environmental, Social, and Corporate Governance (ESG) commitments and related reporting. How do CSR and ESG initiatives compare, and can they coexist? How can organizations evolve their programs and meet compliance requirements?
As compliance officers look to navigate these complex issues, many are finding that incorporating CSR and ESG programs into their compliance training initiatives is an effective way to enable employees, customers, partners, and other stakeholders to take part in work that is bigger than all of us, and manage the risks better and differently.
“In business, we keep score with money. But business isn’t about money — it’s about people. And people long for something way bigger than just money. I’m so proud and thankful to be on a team with associates and owners who continue to use their business success as a springboard to be significant in their communities,” said Ace Hardware President and CEO John Venhuizen in a recent sustainability report.
Publishing an annual sustainability report is one of the main ways that organizations share their progress in these areas – and communicated key information about their corporate culture, commitment to employees’ mental health, and social responsibility efforts. Compliance must be a key component in that culture.
Cultivate a Community of Ethical Leaders
How does one communicate an organization’s ethical beliefs and values to all team members so everyone is aligned on the behaviors expected of them within their organization? How do they promote employee safety and well-being across the company? How do they make hard choices to do the right thing every day?
These guidelines are often communicated via the organization’s Global Code of Conduct, which is a necessary first step for every manager and leader, but not sufficient to fully encompass the behaviors an ethical leader must exhibit.
“Ethical leadership is a long-term win,” noted Catherine Razzano, Head of Global Legal Compliance at TikTok, in a recent conversation on the topic. “There is an enormous amount of pressure in our global environment to make fast decisions.” She recounted watching the Hulu series, The Dropout, about Elizabeth Holmes and her company, Theranos.
The evening before Theranos’ meeting with pharmaceutical giant Novartis, Holmes made a decision to falsify an important blood test – likely thinking that the poor test results would ultimately be resolved, and the short-term ethical breach would justify the long-term gains. However, this decision soon ballooned out of her control.
No decision is ever black and white. Catherine said, “Macro- and micro-environments in the world impact our ability to make the right decisions and show vulnerability. To compensate for that, we need to be more deliberate about the decisions we make.”
It is important for leaders to be able to communicate an organization’s ethical beliefs and values to all team members, so that everyone is aligned with the behaviors expected of them within their organization. They must promote employee safety and well-being across the company and be able to make difficult ethical decisions on behalf of the company.
Here’s a Quick Recap of What We Learned in 2022
So, here you have it. Four things that our clients taught us in 2022 that we plan to take with us into the New Year:
- Train Your Team “In the Flow of Work”
- Remove Training Silos
- Incorporate ESG into Your Online Compliance Training
- Cultivate a Community of Ethical Leaders
Let us know if you have any questions about how to get started on any of these initiatives – we’re happy to pass along some of the tips and tricks we’ve learned, as well.
In the meantime, as holiday shopping moves into full swing, remember to return your shopping carts.