Beg, Borrow, or Steal: Do What It Takes to Make Your Compliance Training Program Successful
You don’t have to reinvent the wheel to make your compliance training program a success. In fact, your peers – and the best practices they have incorporated into their compliance training initiatives – might be one of the most valuable resources available to you as you build out your program.
At Compliance Week National 2023, I had the opportunity to swap ideas with a brilliant group of compliance professionals as I moderated a panel titled, “Beg, Borrow, or Steal: Do What It Takes to Make Your Compliance Training Program Successful.”
- Allison Rubenstein, Sr. Manager, Learning & Leadership Development, Accenture
- Angee Kerns, Sr. Associate, Ethics & Compliance, Booz Allen Hamilton
- Forrest Deegan, Chief Ethics & Compliance Officer, Victoria’s Secret & Co.
Compliance professionals may hesitate to share their training challenges for various reasons, ranging from confidentiality and liability to organizational dynamics. But sharing both our challenges and successes is one of the best ways to make our profession collectively better.
This culture of learning from each other, when effective, can be the most effective control we have to ensure our teams have the technical skills they (and we) need to be competitive, the business and leadership skills they need to respond to new and unexpected challenges, and the knowledge of risk, compliance and ethics they need to stay safe and support our corporate mission.
That’s why it’s critical to know what your peers are doing. Is it working? Can you replicate it? Should you?
Advice for Compliance Professionals
To kick off our panel discussion, I asked our panelists to get real about their compliance training programs. Specifically, I wondered what these compliance leaders would suggest that people beg, borrow, or steal from their compliance training programs. What are they doing right that others might replicate?
Here’s what they told me:
Empower your organization’s natural leaders.
Forrest Deegan, Chief Ethics & Compliance Officer, Victoria’s Secret & Co., mentioned that a best practice is to focus on both “speak up” and “listen up” activities when developing compliance training. Looking at both activities together clarifies when and how to empower managers.
“Compliance professionals need to understand that employee feedback or questions around compliance training don’t always make it back to the compliance team,” said Deegan. “Managers will see it, and it is our job to prepare them to respond to it.”
According to Deegan, the best way to do this is to acknowledge the role that managers will play with respect to your training content – which varies based on audience, location, etc. – and empower them with the information they need to be effective and fulfill their duties.
Reinforce ethical behavior every day.
Compliance training should align with an organization’s values and culture. By emphasizing these values during the training, employees are more likely to internalize and apply them in their daily work. This alignment helps create a consistent ethical framework across the organization.
“One of the best ways to reinforce ethical behavior is to encourage learning in the flow of work,” said Allison Rubenstein, Sr. Manager, Learning & Leadership Development, Accenture. “Think about ways to enable learning connections every day – whether it be by providing employees with scenarios, discussion cards, prompts to use at client sites and with project teams, or something else.”
Training programs can provide clear guidelines on acceptable behavior, outlining what is considered ethical and what is not. By setting explicit expectations, employees can better understand the boundaries of ethical conduct in their day-to-day work. By presenting realistic real-life scenarios, employees can learn from representative experiences to develop a deeper understanding of the impact of their choices on ethical outcomes.
Performance evaluations and rewards can be linked to ethical behavior, creating incentives for employees to prioritize ethical conduct. Said Rubenstein: “Recognizing and rewarding employees who consistently demonstrate ethical behavior reinforces your organization’s commitment to ethics and encourages others to follow suit.”
Identify specific risks in collaboration with other internal stakeholders.
At Accenture, the expectation is that all 750,000+ people globally are taking compliance training each year. This number is not sustainable unless all stakeholders – from legal to compliance to employee relations and more – are working collaboratively to determine the biggest risk areas across the organization.
Working together helps us to avoid communication breakdowns, competing goals and interests, lack of engagement, resource constraints, confidentiality and security risks, cultural and organizational differences, and a lack of accountability. Compliance training is not a “compliance problem,” it is an opportunity for entire organizations to come together to mitigate risk.
Rubenstein mentioned that it is important to work together to figure out who needs what training, and when. “We’ve found it useful to create smaller, segmented audiences based on career level and role, as well as offer short trainings – ten-twenty minutes, tops! – spaced over multiple months,” said Rubenstein.
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Key Takeaways From Other Compliance Programs
After hearing the useful advice taken from their own compliance training programs, I asked our panelists to talk about what they have begged, borrowed, or stolen from others in the industry. The responses were useful.
Focus your efforts.
Angee Kerns, Sr. Associate, Ethics & Compliance, Booz Allen Hamilton, weighed in with some insight her team learned from Home Depot. Said Kerns, “Every month we create topics of the month for employees to focus on. This helps us to home in on areas of particular risk.”
Kerns mentioned that the most effective compliance training programs are based on “push and pull.” Compliance professionals must push mandatory, regulated training content to employees as a baseline. But they must also pull in feedback – in Kerns’ words, “become a sensing organization” – to fill their training calendar with other topics that are relevant and necessary to certain groups in the organization.
“The key is to keep training targeted,” said Kerns. “Keep it short. Keep it relevant to the audiences you have targeted.”
Be transparent in your successes.
Kerns also pointed to the military tradition of “challenge coins” as a source of inspiration. Challenge coins are a military symbol of honor; they signify that the recipient has played a special role and made a significant impact on their peers and the organization.
Booz Allen Hamilton uses “values stones” that recognize employees that embody the company’s purpose, Empower People to Change the World®, and values, one of which is Ferocious Integrity. This is one of many ways that they highlight employees that serve as inspiration to the rest of the team.
“When our people know what ‘doing right’ looks like,” said Kerns, “they can replicate it.” Consistency is key, and transparency paramount.
Performance evaluations and rewards can also be linked to ethical behavior, creating incentives for employees to prioritize ethical conduct. Recognizing and rewarding employees who consistently demonstrate ethical behavior reinforces the organization's commitment to ethics and encourages others to follow suit.
Knowing when, where, and how to create a culture of learning can be a challenge. That’s why you need to know what your peers are doing: Is it working? Can you replicate it?
Always be learning from each other!