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FCPA Compliance Report

FCPA Compliance Report-Episode 441, Compliance Training to Influence Behavior

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:

  1. How did they create some of the most innovative compliance training?
  2. How can innovative training be effective training?
  3. How can compliance training influence behavior?
  4. Why does Galvin (and Ab-InBev) emphasis compliance training so robustly?
  5. How can non-traditional approaches to compliance training be effective?
  6. Why compliance officers should always be curious?
  7. 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.

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Compliance Into the Weeds

Compliance into the Weeds: Episode 131-Compliance Training

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

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FCPA Compliance Report

FCPA Compliance Report-Episode 436, Justin Muscolino on Creating eLearning Training

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:

  1. Why do organizations struggle so much with culture and what impact can compliance training have to improve this?
  2. What do organizations often get wrong when it comes to training?
  3. What happens when organizations do not target their training?
  4. 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?
  5. 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?
  6. 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.

Categories
Excellence in Training

Establishing Your Program Design Objectives

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.
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.
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
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.
Categories
Excellence in Training

Envision Your Compliance Training Program

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:
  1. Decide on the program’s guiding principles
  2. Establish program design objectives
  3. Develop a style guide or set of course standards
  4. Determine the exact risks that will be addressed by the training program
  5. 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.
Categories
Innovation in Compliance

Making Compliance Training Fun with Andrew Rawson


What if compliance training didn’t have to be boring? Joining us on this episode is Andrew Rawson, the Chief Learning Officer for Traliant, a compliance training company. Today we’re talking about the future of compliance training: how to make it truly effective, useful, and even fun.

The importance of training
The last couple of years have seen the intersection of two seismic forces that have created tremendous demand for quality training. The first was the #MeToo movement, which has brought up the whole topic of compliance training around sexual harassment — so much so that it’s become a need to have instead of a nice to have, even in states where it isn’t required. The second was a change in regulations in different states across the country, now requiring more than 10 million people to be trained.
Effective compliance training
There is a difference between teaching people about the law and teaching them what to do. At Traliant, they wanted to train people how to behave. What do you do when you’re faced with a particular situation? That should be the focus.
The training is also intentionally more modern: well-designed interfaces, interactive videos, professional actors, point systems, getting senior management to record training segments for their peers  — all of which help make learning more engaging.
An important part of making training effective is making sure that people are encouraged to speak up, and that when they do, they’ll be protected. You might not be able to stop bad actors, but you can encourage witnesses to point out the behavior.
Moving away from check-the-box training
Much of compliance training is very check-the-box: a once-a-year thing that companies do to get it over with. But that’s not an effective approach. Traliant has gone from doing one-and-done sessions to creating a more holistic training approach. Examples are 15-20 minute courses for managers involved in investigations and two-minute training videos on dating in the workplace that they call “sparks” — because they’re meant to spark conversations.
Preventing Workplace Sexual Harassment: 4 Top Trends for 2019

  1.  The Equal Employment Opportunity Commission (EEOC) is keeping workplace harassment training front and center, remaining one of its top priorities.
  2. Harassment training continues to evolve, and we’re seeing a shift from helping companies avoid liability to helping people behave properly.
  3. Training is highly state-driven, given their different requirements. So Traliant has built a platform where people can access the training relevant to them, instead of a one-size-fits-all course.
  4. There is a focus on building respectful, inclusive work cultures that embrace compliance training not because they have to, but because they want to.

Resources
Andrew Rawson (LinkedIn)
Traliant (Website)
Preventing Workplace Sexual Harassment: 4 Top Trends for 2019