Tag: compliance training

Categories
Blog

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 1- The Importance of Ongoing Communications

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer Success at Diligent; Kevin McCoy, Customer Success Manager at Diligent; Jessica Czeczuga, a Principal Instructional Designer; Andrew Rincon, Global Accounts Management Advisor at Diligent; and David Greenberg, former CEO and Special Advisor at LRN and Director at International Seaways. Over this series, we will consider the importance of ongoing communications, the value of targeted training, training third-parties, and the role of the Board of Directors. In this Part 1, we consider the importance of ongoing communications with Kunal Agrawal.

Compliance professionals are often tasked with the challenge of keeping employees up-to-date with changing rules and regulations while also fostering a culture of accountability. To achieve this, it is essential to develop targeted ongoing communication strategies that resonate with diverse audiences and drive compliance. Through regular cadence of communication, utilizing various mediums, and taking into account cultural nuances, you can ensure that your organization stays ahead of compliance risks and fosters a culture of trust and integrity. Here are the steps to get improved compliance through effective ongoing communication.:

1. Establish a regular cadence for communications
2. Develop customized messages for diverse audiences
3. Utilize various communication mediums effectively

1. Establish a regular cadence for communications. Establishing a regular cadence for communications is a crucial step in achieving effective ongoing communication in compliance. With the ever-increasing complexity of regulations, compliance professionals need to ensure that employees are kept up-to-date on new developments and requirements. A predictable pattern and schedule for communications can help to instill the habit of ongoing communication among employees and stakeholders, ensuring that they are well-informed and prepared to adhere to necessary guidelines. This regularity allows audiences to anticipate and expect updates, making it more likely that they will engage in and retain the information being shared. By maintaining a consistent schedule, compliance professionals can create a conducive environment for the organization to thrive in terms of meeting regulatory guidelines and staying compliant with the latest rules and developments.

Agrawal emphasized the need to maintain regular ongoing communication, as this allows organizations to address the constantly evolving landscape of technology, data privacy, healthcare regulations, and trading compliance challenges. He suggested maintaining a consistent pattern for communications, such as sticking to a set schedule, to create a pattern and habit for employees to follow. Agrawal also acknowledged the importance of customizing these communications across different mediums and using visual aids when appropriate to cater to the needs of different geographical locations, diverse employee profiles, and varied cultural backgrounds. It is essential to establish a regular cadence for communications, as this fosters a culture of compliance and increases employees’ understanding of the guidelines, expectations, and best practices relating to their roles.

2. Develop customized messages for diverse audiences. Ongoing communication in compliance is essential for fostering a strong culture of adherence to regulatory guidelines and instilling the habit of continual learning among employees and stakeholders. With the ever-changing landscape of regulations in various sectors, it becomes increasingly important for compliance professionals to create well-formulated communication strategies that cater to the diverse needs of their audience. One crucial aspect of these strategies is developing customized messages that cater to the unique cultural nuances, roles, and learning preferences of the different members of the organization. By personalizing the content, compliance professionals can ensure that the information is more relevant, engaging and impactful, resulting in more effective communication and, ultimately, better compliance outcomes.

Agrawal focused on the importance of tailoring compliance communications to the specific needs and cultural contexts of diverse audiences. He noted that the ever-evolving nature of technology, data privacy, healthcare regulations, and trading compliance demands that compliance professionals consistently create and deliver content that truly resonates with their audiences. Agrawal highlighted the need to validate internal content with local audiences to guarantee the appropriateness and relevance of the materials.

3. Utilize various communication mediums effectively.  Utilizing various communication mediums effectively is a crucial step in creating an ongoing communication strategy for compliance professionals. With the rapidly changing landscape of regulations, particularly in industries such as technology, data privacy, and healthcare, it is essential to ensure that employees and stakeholders are aware of the latest requirements and guidelines. To achieve this, compliance professionals must adopt a diverse range of communication channels that cater to different audiences, geographical locations, and cultural sensitivities. This includes not only relying on traditional methods such as emails and newsletters, but also embracing newer technologies and platforms, such as instant messaging apps, internal document repositories, and video conferencing tools. By doing so, the compliance professionals can ensure that relevant and timely information is disseminated effectively and efficiently, thereby promoting a culture of compliance and reducing the risk of non-compliance.

Agrawal elaborated on the importance of identifying the right communication mediums to deliver compliance messages effectively. Promoting a culture of continuous communication, Agrawal stressed the need to maintain a regular cadence for communications to create a predictable pattern and habit. This enables the target audience to anticipate and be more receptive to the information shared. Agrawal emphasized the significance of tailoring communication to cultural nuances and appropriateness, particularly with regard to humor. He recommended validating content with a local audience, ensuring that humor is presented effectively and does not alienate or offend the intended recipients.

For compliance professionals striving to maintain a seamless flow of crucial regulatory information, a strategic and robust communication plan cannot be undermined. From our discussion with Kunal Agrawal, we distilled the essence of achieving improved compliance communications. Through regularly engaging with stakeholders in a tailored manner, leveraging multiple communication mediums, and staying attuned to feedback and cultural nuances, compliance officers can ensure that their messaging is accurate, relevant, and impactful. We encourage you to take these invaluable insights to heart, and empower yourself to craft and refine communication strategies that will drive your organization towards compliance excellence.

For more information go to http://diligent.com/compliancetraining.

Join us tomorrow where we consider the value of targeted training.

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Compliance Training From the Movies

If there is one truism from the practices of law which translates to the practice of compliance, it is that your imagination only limits you. Marc Havener, founder, and CEO of Resonate Pictures, Inc., created a series of video shorts for a consulting company on compliance and ethics. Rather than the traditional legal approach of telling employees about the corporate policy on compliance, they wanted to tell a story about compliance through the art of movie-based storytelling that wove messaging into characters to tell a story.

I have urged compliance practitioners to bring more storytelling into their compliance messaging. If you put the employee in the shoes of the person they’re watching, they will remember it because they will see how it applies to their lives. Havener noted that the training experience would last “exponentially longer than if you just go over a written policy or show a PowerPoint.” He called it “expanding your classroom.” The next time they see George Clooney, they’re going to remember the training, the next time they watch that movie that you showed a clip from, they’re going to be reminded of the training, and so it becomes a great drift method of training.”

Three key takeaways:

  1. Storytelling is another form of communication.
  2. Movie clips in compliance training can provide useful touchstones that employees can relate to for compliance lessons.
  3. The Morgan Stanley declination gave credit for annual compliance reminders.
Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Measuring Compliance Training Effectiveness

Since at least 2017, the DOJ has emphasized the need to determine compliance training effectiveness. In the 2020 Update, it stated under the section entitled “Form/Content/Effectiveness of Training” the following questions, How has the company measured the effectiveness of the training? Have employees been tested on what they have learned? How has the company addressed employees who fail all or a portion of the testing? Has the company evaluated how much the training impacts employee behavior or operations?

The DOJ enshrined the importance of determining the effectiveness of your compliance program in its 2020 Evaluation. The 2020 Evaluation demonstrates that the DOJ wants to see evidence of the effectiveness of your compliance program. This is something that many CCOs and compliance professionals still need help to determine. Both the simple guidelines suggested herein, the more robust assessment, and the results provide you with a start to fulfill the precepts set out in the 2020 Evaluation, but you will eventually need to demonstrate the effectiveness of your compliance training in the future.

Three key takeaways:

  1. You must demonstrate that you have measured the effectiveness of your compliance training.
  2. The DOJ is moving into requiring a demonstration of the effectiveness of compliance training.
  3. You should be moving towards a model of demonstrating compliance training ROI to validate the full operationalization of your compliance training.
Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Compliance Training Frequency

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: 

  1. Have a well-reasoned approach to training frequency.
  2. Lengthier, more full-bodied training can be given once every three years.
  3. Shorter, more frequent compliance refreshers or reminders can be used to keep the risk top-of-mind.
Categories
Great Women in Compliance

Great Women in Compliance – Nicole Di Schino – The Compliance Education Fanatic

Welcome to the Great Women in Compliance Podcast, hosted by Mary Shirley and Lisa Fine.

Most E&C professionals know that you can have the best practices and policies, but if they are not understood by your employees and teams, they cannot be effective. And some of us, like today’s guest, Nicole Di Schino, help us with that next step in our training programs. She calls herself the “Compliance Education Fanatic,” and you will understand why after hearing this episode. Nicole discusses the importance of having creative and interactive training, and also how using training with a choice of a “best” answer is better than letting people pick a clear right answer.

Nicole and Lisa also talk about how different ways to communicate with and provide training for those in different generations, particularly with Gen Z.

You can find the Great Women in Compliance Podcast on the Compliance Podcast Network where you can find several other resources and podcasts to keep you up to date in the Ethics and Compliance world. You can also find the GWIC podcast on Corporate Compliance Insights where you can learn more about the podcast, stream prior episodes, and catch up on Mary’s monthly column “Living Your Best Compliance Life.”

Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Compliance Training Governance Committee

One issue that needs to be considered by compliance professionals around compliance training is compliance training governance. Yet a multinational organization subject to the FCPA faces many legal and regulatory risks, and often many of those risks are “owned” by organizations outside the compliance function. How can your organization create a comprehensive compliance training program covering its risk profile?

Every multinational organization will have a broad risk portfolio typically owned across the organization. Consider compliance risk, fraud risk, reputational risk, financial accounting risk, and discrimination risk. These are a small sample of risks; many will not be “owned” by the corporate compliance function. This presents a real challenge when creating a comprehensive compliance training program covering a company’s legal, regulatory, compliance, and reputational risks. Well-know compliance training maven Shawn Rogers suggests “establishing a corporate Compliance Training Governance Committee that looks at the company’s overall risk profile and builds a cross-functional and comprehensive multi-year training plan that effectively addresses all of the risks in a company’s risk portfolio.”

A Compliance Training Governance Committee will allow your organization to effectively establish a multi-year training plan, help in vendor selection and engage in course creation. Rogers said, “One of the biggest benefits has been its predictability to the compliance training program. Every stakeholder from a risk-owning organization knows exactly when their function will have their course deployed over the three-year calendar. They can plan resources, they have a long lead-time to develop the courses, and during their off-years, they can do communications campaigns and events to keep their risk top-of-mind.”

Three key takeaways: 

  1. Why your organization should create a Compliance Training Governance Committee.
  2. Who should be on the Compliance Training Governance Committee?
  3. How should the Compliance Training Governance Committee work going forward?
Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – 10 Compliance Training Program Design Objectives

Well-known compliance training guru Shawn Rogers has developed ten design objectives for establishing your compliance program training design objectives. It would be best if you considered doing the same for your organization. Your organization may value other objectives. What the government has told us since the original FCPA Resource Guide back in 2012 is that it expects a well throughout the approach. If you consider your design objectives early in the planning phase, it will not only meet this requirement but also become a roadmap for your program implementation easier. Finally, you can pivot more quickly in this new era as new compliance risks emerge.

Three key takeaways:

  1. What are your design objectives?
  2. They should be dynamic, not static.
  3. You should use them as touchpoints going forward.
Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Envisioning Your Compliance Training Program

How can you begin to think through a best practices compliance training program? I asked Shawn Rogers, training guru, expert, and maven. Rogers advised that you ‘envision’ what your training would like as a first step. He stated, “A common mistake is jumping right to the question is which courses you want and how to deploy them. However, you must consider several things before building the program.”

You should develop some principles on what your compliance training will look like. A key way to start is by reference to the Training and Communications section of the 2023 ECCP, which states, “Prosecutors should assess the steps taken by the company to ensure that policies and procedures have been integrated into the organization, including through periodic training and certification for all directors, officers, relevant employees, and, where appropriate, agents and business partners. Prosecutors should also assess whether the company has relayed information in a manner tailored to the audience’s size, sophistication, or subject matter expertise.

Some companies, for instance, give employees practical advice or case studies to address real-life scenarios, and/or guidance on obtaining ethics advice on a case-by-case basis as needs arise.” Some of these principles include the following, What are the Guiding Principles of your compliance training? What are you trying to communicate? Is it a broad set of values you want to speak to every employee about what your organization stands for? As noted in the 2023 ECCP, a company should “examine whether the compliance program is being disseminated to, and understood by, employees in practice to decide whether the compliance program is “truly effective.”

Three key takeaways:

  1. The 2023 ECCP has a strong emphasis on compliance training.
  2. Create a set of Principles for your compliance training programs.
  3. You should always use the Guiding Principles of your compliance training program to make decisions.
Categories
Innovation in Compliance

Frictionless and Engaging Compliance Training with Avi Singer

On this week’s episode, Tom’s guest Avi Singer talks about how to make it easier for employees to understand and complete compliance training. Compliance training refers to the process of educating employees on laws, regulations, and company policies that apply to their day-to-day job responsibilities. The goal is for everyone in an organization to have compliance training, and for it to be frictionless for employees to access and complete. 

Avi Singer is the founder and CEO of Showd.me, a company that is helping organizations provide remote and on-demand compliance training solutions, specifically in the healthcare space. He is extremely passionate about highlighting the importance of compliance training, noting that it is often required in order for organizations to comply with regulations. He is described by his colleagues as a “bright professional who can understand complex business solutions and offer creative solutions to problems.” 

 

Here are some key points Tom and Avi talk about:

  • Avi explains how he persuades clients to utilize resources from his company Showd.me to have their employees take its compliance training. 
  • Avi believes compliance training should be easy to understand and pass a quiz on. 
  • The government expects targeted compliance training to address issues like racial sensitivity or harassment, Avi explains to Tom. 
  • Avi highlights the importance of bystander intervention and mandated reporting in potentially harmful situations and the best way to execute it in a clear and nuanced fashion.
  •  If additional training or intervention is required, Avi says, companies should have an HR person who can help address investigations and create policies around compliance.
  • AVI discusses pronoun training, how it should be conducted in order to get the message to the right person, and how to ensure employees are addressed in an appropriate manner.
  • The goal is for everyone in an organization to have compliance training, and for it to be frictionless for employees to access and complete, Avi says.
  • Cost savings can be achieved by reducing liability and risk, as well as by making compliance part of the normal training process.

 

KEY QUOTE:

“You don’t have to be perfect. I think that our training is not like, ‘Hey, you need to know the nuances of harassment or the nuances of what constitutes the mandatory reporter situation or what constitutes abuse’. It’s more like, ‘The law says if you see this going on you have to do something’.” – Avi Singer

 

Resources

Avi Singer | LinkedIn | Twitter 

showd.me 

Categories
31 Days to More Effective Compliance Programs

Day 13 – Podcasting for Compliance Training and Communication

If there is one truism from the practice of law which translates to the practice of compliance, you are only limited by your imagination. This holds in the 360-degree realm of communication in compliance, as communication comes in many forms. Many compliance practitioners will well remember the 2012 Morgan Stanley declination. In this first declination made public, the Department of Justice (DOJ) recognized Morgan Stanley for emailing out 35 compliance reminders to Garth Peterson over seven years. Think about the power of 360 degrees of communication in the context of compliance reminders. Now imagine the power of short ethics and compliance video training clips going out over the same time and the effect it would have on your employees and the regulators.

  1. Podcast Storytelling

Why not tell the story of compliance through a podcast? I call it podcast storytelling, and it can be a powerful tool. Each podcast series is 5-part series and constitutes one story arc. The podcasts are about 10-15 minutes in length. The podcast storytelling series can be a variety of interviews led by a noted podcast host such as the Voice of Compliance, yourself as the Chief Compliance Officer (CCO), or anyone from your organization. It can be an interview with one or more people, or it can be a solo podcast.

A series such as this allows your organization to tell a story more effectively and reach a much larger audience than in any other format; live, audio-video, or in-person. Yet there is another reason you should consider this approach for compliance training and communications. It will provide you with the equivalent of market research and feedback. The number of listeners and downloads will give you a reliable data source for other communications and training.

2. Compliance Department Branded Podcasts

Want another option? How about a fully produced branded podcast series for your internal compliance function? It could be two 25–30-minute episodes per month, with the guest selected by your compliance team. This format allows your corporate compliance function to tell the story of its greatest asset, its people, through interviews. Cannot get out of the country to travel? Still, working remotely? Your branded podcasts allow you to reach your employees as we struggle through the Covid-19 variants. You can use the branded podcast to tell the story of compliance successes in your organization; you can also include other departments to share their successes. As with the podcast storytelling series, it would be done collaboratively with your comms team.

3. Compliance News of the Day

Want to make some short and snappy compliance communications? How about ‘Compliance News of the Day’? Have a daily curated news show of 3-4 compliance stories with a summary of each story and how they relate to a compliance perspective of your organization. Make it fun, so your employees want to check in daily. When the DOJ comes knocking and asks how often you send compliance communications, you can point to your Compliance News of the Day as a great starting point.

As a compliance practitioner, you should strive to bring more storytelling into your compliance messaging, training, and communications. If you put the employee in the shoes of the person they’re watching, they will remember it because they will see how it applies to their lives. Training and communication experiences will last much longer than if you drone over a written policy or show a PowerPoint. Marc Havener has called this “expanding your classroom.” Ronnie Feldman calls this bringing memorable storytelling to your compliance communications and training.

Since your imagination only limits you in compliance, why not use some of that to be creative in your compliance training and communications?

 Three key takeaways:

1. Using podcast storytelling to tell longer, more involved stories about compliance.

2. You can use compliance department-branded podcasts to have ongoing communications about compliance.

3. A Daily Compliance News show will drive engagement.