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.
