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Excellence in Training

Measuring Training Effectiveness

In this episode of Excellence in Training, Shawn Rogers provides some of this thoughts on measuring training effectiveness.
To measure the effectiveness of a compliance training program, you can’t come up with a metric that measures how many violations it prevented. Everybody knows intuitively that training helps prevent compliance violations. Again, that measurement is too far removed from the purpose of the compliance training program. However, it would be a good metric for the overall training program if you could figure out how to do it.
But how often do you see companies reporting the number of classes that were delivered? Or how many hours of compliance training were completed? It happens all the time. It could be a completely accurate statistic. It could be a measure of compliance program efficiency. It could be an indicator of an active compliance training program. But it in no way shows if the compliance training is effective.
But there are ways to measure training effectiveness. You can show that the training was aligned to the company’s risk profile. With user surveys and focus groups you can measure whether the learners feel that the training is applicable to their role and you can measure user satisfaction. You can ask learners to give examples of how they have changed the way they do their jobs.
Why don’t companies do a better job in measuring the effectiveness of compliance training? Because it’s very challenging to do. But there are ways to do it. Shawn conclude with one of his current ‘most favorites’ implemented at GM this year.
At GM there is a cybersecurity course that explains how to avoid phishing email scams. It is required of all employees that have a GM email account. To measure how effective the training was, the IT function came up with a method of sending out emails to random batches of employees that should have been recognized as phishing emails if they had paid attention to the training. If the employee recognized that the email was suspicious and clicked on the “Report Phishing” button, they were congratulated on reporting the email as suspicious. However, if they clicked on the link in the email, the IT team knew that the training had not met its objective. And, those employees that clicked on the link were kindly informed that they had failed the competency test and were provided with immediate feedback on how to avoid phishing scams.
Disclaimer-As a company, GM uses many training vendors. GM’s compliance function primarily uses two vendors. Rogers has worked with other good vendors that currently do not work with GM. Rogers is not promoting any specific vendors, nor is he disparaging any specific vendors in this podcast. And, of course, these opinions are Roger’s alone and opinions that  developed over almost 15 years. He is not speaking on behalf of GM in any way.
Categories
Daily Compliance News

October 18, 2019- the CITGO sign edition

In today’s edition of Daily Compliance News:

  • Aramco IPO delayed yet again. (WSJ)
  • Swiss trade fined for bribe payments to DRC leaders? (Bloomberg)
  • When will the CITGO sign go down? (NYT)
  • FASB delays implementation of new accounting standards. (WSJ)
Categories
FCPA Compliance Report

Why Culture Matters-Episode 4, How Does a Company Assess its Culture?

Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists in the space between what an organization professes and what it does. In this series Jay and I will be exploring key aspects of corporate culture, including why it matters, what influences culture, the CCOs role in culture, assessing corporate culture and how to use that information to improve culture. In this Part IV, we consider how to assess your corporate culture. 
Highlights include:

  • Who should perform the assessment of corporate culture?
  • An in-house resource may be seen as more ongoing monitoring than culture assessment.
  • Conversely an independent outside expert may be able to garner more fulsome information of the true state of your corporate culture.
  • Tools to assess the culture of an organization include employee surveys, conversations, visits to field operations.
  • What are the differences, if any, which must be considered when assessing a global company?
  • Why do you need to “fine-tune” a cultural survey to get a good understanding of the company’s culture and obtain meaningful metrics?
  • The bottom line is you should take the temperature of your employees internally by doing regular monitoring of your company to understand its culture and what needs to be done.

Please join us for our concluding Episode 5, where we bring it all together and consider how ethical culture is a part of an overall ethics and compliance assessment.
For more information see Jay’s blog post How does a company assess its culture? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. check out their website here.

Categories
12 O’Clock High-a podcast on business leadership

Leadership Lessons from the Mississippi Bubble of 1720

I recently listened to the Great Courses series of lectures, entitled Crashes and Crisis: Lessons form a History of Financial Disasters, hosted by Professor Connel Fullenkamp. Although the lecture series focused on economic disasters, I found many leadership lessons embedded in the lecture. In prior podcasts, host Richard Lummis and myself have considered the Dutch Tulip Bubble from the 1630s and the South Sea Bubble of 1720. Today we consider the leadership lessons and failures which led to the Mississippi Bubble of 1720.  The Mississippi Bubble has nothing to do with the state of Mississippi or the great river but rather a French trading company which had been granted an exclusive charter by the King of France to develop France’s territory in the Mississippi territory in the New World.

Categories
Daily Compliance News

October 17, 2019- the $50bn edition

In today’s edition of Daily Compliance News:

  • Broadcom ordered to stop anti-competitive practices in Europe. (WSJ)
  • Is it real or is it payback? (Washington Post)
  • Will big pharma pay $50bn to settle opioid litigation? (NYT)
  • Wirecard’s fraudulent accounting practices revealed. (FT)
Categories
FCPA Compliance Report

Why Culture Matters-Episode 3, the Role of the CCO in Culture

Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists in the space between what an organization professes and what it does, yet who bears the responsibility for establishing and maintaining an ethical culture? In this series Jay and I will be exploring key aspects of corporate culture, including why it matters, what influences culture, the CCOs role in culture, assessing corporate culture and how to use that information to improve culture. In this Part III, we consider to what extent the Chief Compliance Officer (CCO) should be involved in shaping a culture of ethics and driving ethical behavior.
 Highlights include:

  • Who bears the responsibility for culture?
  • The duty most often falls to the CCO, so both the CCO and the entire compliance function need to be able to coordinate the various inputs and support mechanisms that guide employee behavior.
  • The CCO is often the face of the ethics program for the company – kind of the spokesperson for the company who helps to drive behavior.
  • In hiring and recruiting, a CCO can create a culture where an organization would only hire the right type of people as employees.
  • When managing upward, the CCO has an equally critical mandate through unfettered access to provide information to the Board regarding the compliance and ethics posture at the company, specifically including the culture.
  • What are the warning signs of an unethical culture?
  • It is up to the CCO to understand and have their finger on what the culture is, where the challenges are and what needs to be done to continually strengthen the culture.

Please join us for Episode 4, where we explore how a company can begin to assess its own culture.
For more information see Jay’s blog post What is the CCO’s Role in Strengthening the Organization’s Culture of Ethics?on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. check out their website here.

Categories
Great Women in Compliance

Sarah Haddon on Telling Stories of Compliance

Great women in Compliance come from all different backgrounds (we love diversity!) but also don’t necessarily work in Compliance Officer roles.  There are many Compliance related functions that we interact with and benefit from on a regular basis as Compliance professionals. Today we are pleased to feature one of such wonderful examples – Sarah Hadden who is the owner and publisher of Corporate Compliance Insights (CCI).  CCI is a news outlet with articles and featuring podcasts such as the Great Women in Compliance (GWIC) podcast .  The best thing about it is that it’s free to access and Sarah intends to keep it that way.  Which is welcome news for all of us carefully counting our Compliance budget pennies!  Sarah also features on one of our sister podcasts on the Compliance Podcast Network as series regular on Everything Compliance.
We talk about:
  1. Sarah’s decision-making when confronted with several forks in the road.
  2. The CCI origin story and free of charge offerings for Compliance professionals.
  3. Tips for getting an article accepted by a Compliance publication.
  4. Hot topics of the moment… and not so hot topics because they’ve been written about so often it’s the same article re-published over and over – yes we’re looking at you GDPR readiness.
  5. What makes a thought leader.
Lisa and Mary count Sarah as one of the GWIC podcast’s greatest supporters.  She has sponsored several episodes, provides ideas and inspiration for episodes and cheers us on from the sidelines when not in the game as a guest on the show herself!  We are extremely grateful for Sarah’s encouragement and promotion of our podcast on CCI.
Listen in to hear about how Sarah, a trained journalist, found her Compliance destiny.
Check out Corporate Compliance Insights here.
Categories
Compliance Into the Weeds

Changes at the PCAOB

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent changes at the PCAOB made by SEC Chairman Jay Clayton.
Some of the highlights include:

  • Why were the changes announced in a manner to hide them?
  • Why were they such unusual personnel moves?
  • Why would the SEC put someone on the PCAOB with no discernible qualifications for the role?
  • Is the goal of Jay Clayton to do away with SOX 404 protection for investors?
  • Does going public under SOX mandate investor protection?
  • What else will Clayton pull to ram through his changes at the PCAOB and SEC?
  • Why is WeWork such a power example right now?

For additional reading see the following:
Matt’s blog post, PCAOB Shakeup-What it Means for You, on Radical Compliance.

Categories
Daily Compliance News

October 16, 2019- the Doobie Brothers for the HOF edition

In today’s edition of Daily Compliance News:

  • Has Trump administration gutted the PCAOB? (WSJ)
  • Before the NBA stepped in it (in China); the NFL did. (WSJ)
  • Doobie Brothers head list for 2020 Rock & Roll HOF. (Houston Chronicle)
  • Zuma corruption cost South African over $34bn? (FT)
Categories
FCPA Compliance Report

Why Culture Matters-Episode 2, What Factors Influence a Company’s Culture

Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists in the space between what an organization professes and what it does. It is important to pay attention to corporate culture as disconnects in this reality can be quite costly. Yet what factors influence corporate culture. In this series Jay and I will be exploring key aspects of corporate culture, including why it matters, what influences culture, the CCOs role in culture, assessing corporate culture and how to use that information to improve culture. In this Part II, we consider what can influence an organization’s ethical culture, starting at the top with senior leadership. We consider such questions as whether your senior leaders practice what they preach as employees can spot a disconnect from a mile away.
 Highlights include:

  • A company does not have an ethical culture unless top management commits to it.
  • Equally important is a sense of organizational justice and fairness.
  • One of the key elements of effective leadership is listening and that also applies to a company’s culture.
  • Do senior leadership give their people the opportunity to be heard?
  • Do senior leaders get out of the ivory tower, go out into the field and meet with employees?
  • Are there town halls or other types of group interactions?
  • Do the employees see whether their leaders are living those kinds of values?
  • It is crucial for perception to equal reality.
  • The bottom line is there must be alignment between what top management says and the company’s core values – between what the organization says and what it does.

Please join us for Episode 3, where we explore the role of a Chief Compliance Officer in strengthening the ethical culture of the organization.
For more information see Jay’s blog post What Factors Influence a Company’s Ethical Culture? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. check out their website here.