Tag: training effectiveness

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Principled Podcast

Principled Podcast – S9 E20 – What You Measure is What Matters: Training Effectiveness at Dell

What you’ll learn on this podcast episode

Does learning actually occur as a result of ethics and compliance training, or are employees just paying lip service when they take courses? How can you tell the difference? Today, the E&C community is focused on program impact and effectiveness rather than checking boxes—in part because regulators have made it clear that E&C programs must show impact from their activities. On the season 9 finale of the Principled Podcast, Susan Divers discusses how compliance teams can ensure they’re getting the right insights to improve their programs with Kristi Kevern, the senior managing director at Dell Technologies. Listen in as Kristi shares how her team collects and analyzes data to manage better and enhance Dell’s E&C program, particularly in the training area.
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Guest: Kristi Kevern

Kristi Kevern – Grayscale

Kristi Kevern is an innovative thought leader with 20+ years of experience in internal control design, implementation, management, and assurance. At Dell Technologies, Kristi drives enterprise-wide risk management and governance activities, conceptualizes and implements global programs aimed at mitigating FCPA, AML, SOX, ESG, and other key risks, turns findings into fixes with post-investigation remediation, and experiments with AI and ML for further prevention and insights using data. Prior to Dell, Kristi served as a founding member of the Coca-Cola Company’s Ethics Office, where she investigated allegations of fraud and served as an ethics advisor to the credit union. As a former Big 4 manager at PricewaterhouseCoopers LLP, Kristi led assurance and attestation engagements for Fortune 500+ clients. Kristi is a recipient of TRACE International’s Innovation Award, and she has led Dell Technologies to an Ethisphere World’s Most Ethical Company designation 10 times. She is the membership chair of the Conference Board’s Global Business Conduct Council and a frequent speaker at conferences and universities. Kristi graduated with honors from Auburn University and is a Certified Public Accountant residing in Austin, Texas.

Host: Susan Divers

Headshot_Susan_Divers_S7E18_Principled_Podcast

Susan Divers is a senior advisor with LRN Corporation. In that capacity, Ms. Divers brings her 30+ years’ accomplishments and experience in the ethics and compliance area to LRN partners and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.

Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics and Compliance and Chief Ethics and Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program.

Mrs. Divers’ background includes more than thirty years’ experience practicing law in these areas. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath, & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.

Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington, D.C., and the National Law Center of George Washington University. In 2011, 2012, 2013, and 2014, Ethisphere Magazine listed her as one of the “Attorneys Who Matter” in the ethics and compliance area. She is a member of the Advisory Board of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005–2008.

She resides in Northern Virginia and is a frequent speaker, writer, and commentator on ethics and compliance topics. Mrs. Divers’ most recent publication is “Balancing Best Practices and Reality in Compliance,” published by Compliance Week in February 2015. In her spare time, she mentors veterans and university students and enjoys outdoor activities.

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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.
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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.