Welcome to this special podcast series, Integrity Matters: Culture, Training and Compliance, sponsored by K2 Integrity. This week I visit with Koby Bambilia, Managing Director, and Tina Rampino, Associate Managing Director. Over this series, we will break down corporate culture, compliance training and communications. Topics include breaking down the big picture on culture, espresso shots of training, skills development and regulatory changes, tailored and risked based training and operational aspects of training. In Part 2, I am joined by Tina Rampino who discusses ‘espresso shots’ of training to help facilitate attainable training demands.
We began with the status of compliance training after 18 months of Covid-19. Here Rampino noted, “in the early phase of the pandemic, institutions had to quickly change to a fully virtual working environment. They had to find creative solutions to adapt their training programs in response. All planned instructor-led training was cancelled or transitioned to virtual training.”
But what was the impact of Covid-19 on compliance training plans? She said it varied between each organization but “the delays, rescheduling, and redesigning of mandatory trainings to accommodate the virtual working environment caused a big training load and a heavy training burden for institutions. Many institutions delayed mandatory training as they tried to work through issues as mundane as bandwidth as all employees were now remotely logged in to the same Learning Management Systems at the same time every day.” The bottom line is that many organizations pushed training to the end of the year or into 2021 and competing priorities and demands had to be managed. Moreover, we are now into Q3 2021 and even though the virtual work environment has become routine for compliance professionals, the pressure is on to get back up to speed on all those trainings.
If your organization finds itself in that place, Rampino advised on what she called “an espresso shot” of compliance training which can be both shorter and more concise, but drills down to specific risks relevant to an institution. She went on to relate that she has been involved in creating solutions that can deliver shorter and more tailored training which will result in increased relevance to the employee and have a lighter burden of training hours. Rampino said, “The concept of espresso shot training can assist employees to better manage their workload while keeping up with important issues relevant to their roles. For example, institutions should think creatively on delivery and modality of training content. Not only in an e-learning format: something engaging, cartoons, videos, interactive virtual training.”
I think that every compliance professional strives to find the right balance between training on general awareness topics and shorter, more relevant and practical training opportunities. Unfortunately, compliance training is viewed as a “check the box” activity or worse, something that is dreaded and is usually ineffective. Rampino suggested compliance training incorporates real life scenarios, case studies or simulations to give employees an opportunity to learn in a sand box environment and to practice the skills that they are being taught.
Some of her suggestions include keeping your compliance training segments concise as “shorter, bite-size learning is a trend in training programs.” This means that instead of offering half-day and full-day sessions, break programs into shorter segments of 20 minutes or less, which are easier for participants to absorb – and schedule. Another example is that short cartoons or animated videos can be excellent quarterly reminders. Done properly, they do not feel like an assessment or certainly not a ‘check-the-box’ exercise. The bottom line is that with all training most employees must undergo now and even more so in the continued time of the Covid-19 Delta Variant, espresso shots give people back a lot of time.
K2 Integrity has developed an online training platform and resource center, Dedicated Online Financial Integrity Network (DOLFIN), to help clients with their training requirements and provide more diverse options for training content and modalities. Find out more about DOLFIN here. For more information on K2 Integrity click here.
Tag: compliance training
Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network. In this episode, Tom and Ronnie look at the common objections to using comedy in compliance training and communications and debunk them all.
- Well, we’re a conservative company
- We don’t do humor here or we tried humor once and it didn’t work
- Employees already get tons of communications, so we don’t have an appetite for more compliance communications.
- We need to focus on our core training first
- We’re global so humor doesn’t work
Resources:
Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.
Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.
Tales from the Hotline – check out some samples.
Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network. In this show, we discuss how to use creativity your compliance communications to have a more effective compliance program by producing a more robust Speak Up culture in your organization. The recent DOJ 2020 Update to the Evaluation of Corporate Compliance Programs stated the following: Other companies have invested in shorter, more targeted training sessions to enable employees to timely identify and raise issues to appropriate compliance, internal audit, or other risk management functions. How does Speak Up compliance training fit into this new mandate?
Some of the highlights include:
- Why is this change both significant and importantly was is the Government’s expectation? What is the difference between “shorter” and “targeted” training?
- The DOJ has acknowledged what most successful programs have known for a while. That shorter, more frequent training and communications are more effective. Most adult learning principles support this.
- Training is important, but it should be shorter, relevant and interesting.
- Comms is separate. It services a different purpose.
- To advertise where resources are.
- To drive traffic to those resources – teach people where to go.
- To remind people and reinforce resources and themes.
- “Enable employees to timely identify and raise issues”
- That is making resources accessible and easy to use
- Show up in more places – Apps, Newsletters, Intranet Posts, email signature, in the mouths of leadership
- It’s also about making people know that they are safe
- That is making resources accessible and easy to use
- Targeted is focused on making training relevant. Corporate comms can go to everyone, everywhere, all the time. Training should be tactically relevant to job function.
- Learnings and Entertainments creates short stories about specific issues so that companies can deploy those to those specific audiences.
- Broadcat makes job aids which are helpful in this regard.
- Offerings are aligned with what the DOJ is recommending in their 2020 update.
- “Hey maybe a group of comedians and improvisers have something to offer.”
- L&E’s whole business is structured around two things.
- Promoting E&C as helpful advisors and coaches.
- Promoting Speak Up culture.
- Short, Entertaining, Memorable Comms & Awareness – this is designed to raise the visibility of the issues policies and resources so they are easy to access. Show up in more places. Try to shift attitudes and behaviors over time.
- Person on the Street Campaigns – gives voice to employees. Makes it less preachy.
- Stories that shed light on the speak up process – share why things happen and the results of those things. Very specific and targeted learning.
- Talk Shows that help leaders shed light on the speak up process – build trust.
- Improv Training to help leadership encourage speak up culture.
Resources:
Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network to explore these issues. In today’s episode we are joined by Ricardo Pellafone, founder and CEO of Broadcat. We visit with Ricardo about his journey into compliance and why he thinks most compliance training sucks, why it should be ditched and how we all need start over. Some of the highlights include:
- Ricardo’s journey into compliance and what led him to found Broadcat.
- Why is compliance training the worst?
- Why is using the using the right tool for the job critical in compliance training?
- How can compliance training educate?
- Why is it important to target specific behaviors in compliance training?
- Why is awareness and communications so critical when thinking about compliance training?
Resources
Ronnie Feldman
Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.
Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.
Ricardo Pellafone and Broadcat
For more information on Broadcat, click here.
For Ricardo’s LinkedIn profile, click here.
In this five-part podcast series, sponsored by K2 Intelligence FIN, we consider defining and building effective compliance programs. I am joined in this series by Michelle Goodsir, a Managing Director at K2 Intelligence FIN. Gail has 25 years of financial crime compliance experience which includes fraud risk management, anti-bribery and corruption, corporate security and investigations, sanctions, and Anti-Money Laundering (AML) program experience working within the financial services industry and the U.S. government. Gail Fuller is a Vice President at K2 Intelligence FIN. Gail focuses on developing, refining, and implementing FIN’s quantitative and qualitative risk rating tools. She leads engagements focused on helping FIN’s jurisdictional and private sector clients understand their exposure to financial crime risk and develop and implement strategies to mitigate their risks. Over this series we will consider key challenges in compliance, why compliance needs a seat at the table, how to do compliance on a budget, training and culture and what is on the horizon. In this Part 4, I visit with Gail Fuller on how to facilitate ongoing compliance training, communications and re-emphasizing culture in an organization.
Resources
K2 Intelligence financial crimes risk & compliance page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance
K2 Intelligence AML page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-money-laundering-compliance
K2 Intelligence Anti-corruption page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-corruption
K2 Intelligence DOLFIN: https://www.finintegrity.com/dolfin.html
In this episode I visit with Matt Galvin, Vice President, Ethics & Compliance at Anheuser-Busch InBev and Peter Grossman, Co-Founder, Chief Strategist at Labyrinth Training about their work on compliance training to influence behavior at Ab-InBev. Highlights from the podcast include:
- How did they create some of the most innovative compliance training?
- How can innovative training be effective training?
- How can compliance training influence behavior?
- Why does Galvin (and Ab-InBev) emphasis compliance training so robustly?
- How can non-traditional approaches to compliance training be effective?
- Why compliance officers should always be curious?
- How did Matt and Peter come together to create this innovative training regime?
For more information on Peter Grossman, check out his LinkedIn profile here. For more information on his company Labyrinth Training, click here. For more on Labyrinth’s work with Ab-InBev on training, click here.
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 (the coolest guy in compliance) and I go into the weeds to explore Matt’s observations on compliance training. While traveling cross-country with the family for a well-earned vacation he paid close attention to the safety training video. We used that as a starting point for a deep dive into compliance training and communications.
Some of the highlights include:
- What are some fresh takes on compliance training?
- How do you implement both effective and tailored training?
- Is your training procedural? Ethical? Systemic?
- Do you want your employees to follow procedures or standards of behavior?
- Employees need to feel like there is someone listening.
- What is the role of ongoing communications in training?
For further reading see Matt’s blog post-How Good Training Finds its Wings
In this episode of the FCPA Compliance Report, I visit Justin Muscolino, Head of North American Compliance Training Operations for GRC Solution. Some of the highlights include:
- Why do organizations struggle so much with culture and what impact can compliance training have to improve this?
- What do organizations often get wrong when it comes to training?
- What happens when organizations do not target their training?
- One of the issues that organizations face is measuring the effectiveness of their training benchmarking that their compliance is working. How can a compliance professional consider benchmarking?
- In a blog post on the GRC Solutions website you also look at the training compliance professionals to improve their culture? How can you train compliance officers around this issue?
- Any advice for companies trying to get the right culture in their organizations?
You can find more information on GRC Solutions by checking out their website, here.
At GM, we came up with ten design objectives that we felt were important for our training program:
1. Aligned to GM’s top compliance risks. In various guidance documents, you see the term “risk-based.” It’s critical that you design your program to directly address the risks your company faces. We’ll talk more about having a risk-based training program in future podcasts.
1. Aligned to GM’s top compliance risks. In various guidance documents, you see the term “risk-based.” It’s critical that you design your program to directly address the risks your company faces. We’ll talk more about having a risk-based training program in future podcasts.
2.Professionally designed. Face it, compliance training is not pleasant. But it can be even worse if its quality is substandard. Unfortunately, in my career, I’ve had to take some pretty ugly courses. I’m sure many of us can relate. We’ve seen courses that are nothing more than a PowerPoint presentation with some stock images. If we’re lucky, we might have some narration. We wanted more than that with our online courses. We wanted our courses to be visually appealing. We wanted them to be very organized. We wanted them to be professionally narrated. We wanted them to be interactive.
3. Applicable to adult learners. There is a lot of debate about “adult learning theory” and strategies that appeal to various demographics. We wanted the courses to speak intelligently to a sophisticated and experience professional audience. Companies have different cultures, different styles, and different tastes. At GM, we wanted to be formal, but conversational. We wanted to be serious, but not stuffy. We didn’t want our learners to feel like we were talking down to them or treating them like children.
4. Standardized. There are some things that really irritate learners. One of those is a lack of standards between course offerings. Learners don’t want to have to learn how to use different navigation techniques in different courses. This is as simple as standardizing on look-and-feel, location of forward and back buttons, location of resources, types of test questions. One of the advantages of using a training vendor is that it promotes standardization between courses. This is a quick win. If all your courses have a standard look-and-feel, similar learning exercises, and similar kinds of knowledge checks, they spend the time learning rather than trying to figure out how to move through the course. We also wanted to come up with a set of standard languages, and we wanted the courses to reflect GM’s branding guidelines.
4. Standardized. There are some things that really irritate learners. One of those is a lack of standards between course offerings. Learners don’t want to have to learn how to use different navigation techniques in different courses. This is as simple as standardizing on look-and-feel, location of forward and back buttons, location of resources, types of test questions. One of the advantages of using a training vendor is that it promotes standardization between courses. This is a quick win. If all your courses have a standard look-and-feel, similar learning exercises, and similar kinds of knowledge checks, they spend the time learning rather than trying to figure out how to move through the course. We also wanted to come up with a set of standard languages, and we wanted the courses to reflect GM’s branding guidelines.
5. Strategically Planned. A company the size of GM has many risks that could be covered in a compliance training program. In our online training portfolio we have dozens of topics that we need to cover. But you just can’t require dozens of courses each year. There is such thing as training overload. So we decided to map out or risk coverage strategically over a three-year timeframe. Some stakeholders feel like their specific risk is so important that it has to be required every year. We had to get past that and reassume them that they weren’t going to be ignored, but that they needed to accept the fact that their specific topic would be fairly represented in the program over time.
6. Engaging. By engaging, I mean that we wanted the courses to hold the audience’s attention. We want them to be interesting. We want the courses to be relevant to the audience’s situations. We want them to make the learner think.
7. Frequently updated. One of my personal pet peeves, both as a training professional and as a learner, is being required to take the EXACT same course over and over again. I agree that some topics are so important that they have to be repeated. However, that doesn’t mean you can’t keep the courses fresh with different scenarios, different approaches to the risks, different videos, different learning checks. This became one of my cardinal rules. If you are going to repeat a topic in the training program, you’re going to refresh the course. I personally think it’s insulting when I’m asked to take a course twice. To me, nothing screams “check the box” program than requiring the identical course year over year.
8. Non Legalistic. How many times have you been in a training session where the instructor starts out by saying something like, “The five elements of the FCPA are…” The only people that kind of an approach appeals to are the lawyers in the room. I always say that I don’t care if my learners know how to spell FCPA. We aren’t trying to create mini-lawyers. (Do you really want your audience to be making legal decisions?) We are trying to help businesspeople understand how to perform their jobs ethically and within the bounds of company policies and the laws. We try to make sure that our courses speak the language of the business, not the language of the lawyers. (It’s a constant struggle.)
9. Optimized to Eliminate Redundancy. When you require multiple courses in the same year, there’s bound to be some redundancy. As important as a non-retaliation policy is, do you really need to cover it as a learning objective in every single course? Perhaps you can cover non-retaliation in your Code courses, and then just do a short pop-out reminder that we don’t retaliate in the other courses. Your overall goal is to cover the topics adequately while minimizing seat time to respect the employee’s time and company resources.
10. Flexibility
Finally, we wanted our program to be designed for flexibility. For example, it’s very possible that you will get an unexpected requirement to address a risk in year that you had not planned for that risk. A three-year plan can be designed to be flexible and adaptable to a changing risk environment.
Conclusion
Conclusion
Your company might value other things besides those I’ve talked about in this podcast. But if you think about your design objectives early in the planning phase, it will make your program implementation easier. It is also helpful to have these design objectives in hand before you start talking to the vendors who want your training business. You’ll be more likely to find a vendor that will meet your requirements if you go into the discussions with a vision of what you want them to provide.
In this episode of Excellence in Training, Shawn Rogers and I consider how you should envision your training.
Shawn begins his journey with the famous book, The Seven Habits of Highly Effective People, where Stephen R. Covey said, “All things are created twice. There’s a mental or first creation, and a physical or second creation to all things. Take the construction of a home, for example. You create it in every detail before you ever hammer the first nail into place. . . Then you reduce it to blueprint and develop construction plans. . . Begin with the end in mind. ”
This principle applies to creating a compliance training program. A common mistake is jumping right to the question if which courses you want and how to deploy them. However, there are several things you need to think about before you start building the program.
Here are the steps we followed at GM as we envisioned what our compliance training should look like:
Shawn begins his journey with the famous book, The Seven Habits of Highly Effective People, where Stephen R. Covey said, “All things are created twice. There’s a mental or first creation, and a physical or second creation to all things. Take the construction of a home, for example. You create it in every detail before you ever hammer the first nail into place. . . Then you reduce it to blueprint and develop construction plans. . . Begin with the end in mind. ”
This principle applies to creating a compliance training program. A common mistake is jumping right to the question if which courses you want and how to deploy them. However, there are several things you need to think about before you start building the program.
Here are the steps we followed at GM as we envisioned what our compliance training should look like:
- Decide on the program’s guiding principles
- Establish program design objectives
- Develop a style guide or set of course standards
- Determine the exact risks that will be addressed by the training program
- Set up a governance process to ensure stakeholder alignment, approve the program design, approve the budget, and monitor effectiveness.In Covey’s terms, these activities resulted in the blueprint — or the “first creation” — of our compliance training program. We did all of these before we selected our vendor and started building our training courses.