What should be your organization’s compliance training frequency? How can the amount of training positively or negatively impact an overall training strategy? Unfortunately, the 2020 Update or the 2020 FCPA Resource Guide did not answer these questions. Still every company should have a “well-designed compliance program is appropriately tailored training and communications.”
Compliance professionals often think compliance training needs to be conducted very frequently, even if it means repeating the same training courses every year. Compliance training expert Shawn Rogers analogizes compliance training to an automobile’s windshield wiper system in discussing how frequently compliance training should be administered. He explained, “It would not make any sense to run your wipers constantly, even when it is not raining. First, it would be extremely annoying to the passengers. And second, eventually, it would wear out both the wiper blades and the wiper motor. It would simply be nonsensical.” Requiring overly repetitive training is like running your windshield wipers in clear weather. The learners will be annoyed; the training will be viewed as a waste of time and energy. Finally, your employees will not take training as seriously when addressing a specific situation, as the compliance training will be viewed literally and figuratively as a “check-the-box” exercise.
Three key takeaways:
- Have a well-reasoned approach to training frequency.
- Lengthier, more full-bodied training can be given once every three years.
- Shorter, more frequent compliance refreshers or reminders can be used to keep the risk top-of-mind.
