Tag: training

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Great Women in Compliance

Great Women in Compliance: GWIC and Everything Compliance

Welcome to the Great Women in Compliance podcast on the Compliance Podcast Network, sponsored by Corporate Compliance Insights.

In today’s episode, we have a special episode which is cross-posted with Everything Compliance, which we call Ladies Night: Exploring Compliance in All-Female Podcast Takeover.

In this special Ladies Night edition of the Everything Compliance Podcast, guest host Christy Grant Hart is joined by notable women in compliance as guest panelists,  Karen Woody, Karen Moore, Lisa Fine, and Hema Lomax, for an in-depth discussion.

Topics covered include the complexities of Caremark duties and its recent interpretations, Boeing’s ongoing compliance issues, the implications of the Mike Lynch acquittal on due diligence, and ways to enhance the effectiveness of compliance training. The episode wraps up with each guest sharing their raves, offering insights and reflections on the state of compliance today.

  • Karen Woody on Caremark Duties Explained
  • Karen Moore on Boeing’s Compliance Issues
  • Lisa Fine on the Mike Lynch acquittal and HP’s Acquisition of Autonomy
  • Hemma Lomax on Effective Compliance Training
  • Rants and Raves

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Blog

Making Ethics & Compliance Training Memorable: Part 1 – What is the Problem?

There is not much I enjoy more than sitting down with one of the innovative thinkers in compliance, Carsten Tams, to find out what is on his mind regarding compliance. I recently had the opportunity to do so in making compliance training memorable. We explored this topic over this short five-part podcast series on the award-winning Innovation in Compliance on the award-winning Compliance Podcast Network.

Over the next five blog posts, I will also explore these topics in the blog format. I will introduce the problem and challenges and then provide you with four proven strategies for success in your compliance training. I deeply dive into why traditional E&C training often fails to engage employees and needs more impact on their behavior despite significant investments. This episode sets up the problem by exploring the historical context of E&C training, the difference between European values-focused and American rules-regulation approaches, and how these methods have evolved. In Part 1, I provide the lay of the land, explain when ethics training needs some fresh ideas, identify some of the challenges ethics training faces, and conclude with a summary of the solutions.

I think this topic still bedevils many compliance professionals: ethics and compliance training. 15 years ago, compliance training was written by lawyers for lawyers. There was a difference in the European approach, which focused more on values, as opposed to the American approach, which focused on rules and regulations. Hopefully, it has evolved past all of those, but there is still a problem with compliance training’s need to engage employees meaningfully.

Tams even further believes this issue of non-engagement by employees with compliance training is “the billion-dollar elephant in the room for ethics and compliance as a practice.” This problem is even made more critical as compliance training is one of the most important functions that ethics and compliance departments perform. “It is also important in terms of the size of the budget they spend on it. The training and compliance training industry is huge. It’s one of the biggest corporate learning sectors, if not the biggest. And yet here we are, and we have very little. After billions of dollars spent and millions of people going through compliance training, there’s very little evidence that it is working in terms of truly creating a better speak-up culture and truly affecting employee behaviors in any positive sense.”  Tams ended by noting that undoubtedly the thing such training does accomplish “is that we’re able to check that box and say, yes, we fulfilled our requirement to train people. However, I think it is lacking in terms of behavioral impact.”

There are some interesting data points on that. A study by Gallup in 2023 showed that three-quarters of compliance training showed little to no benefit. Another finding was that training only tended to benefit when the learner experienced it very positively. When the learner rated the training experience as excellent, the training positively impacted behaviors. This shows that training experience matters.

Compliance professionals must understand better what makes people engage in this type of training. Navex, in an article entitled Top 10 Reasons Why Compliance Training Fails,  asked why training programs often fail. The answer most frequently given was that training is uninspiring, unmemorable, and usually perceived as irrelevant to learners’ work.

There are four engagement killers in compliance training:

  1. Deficit-Focused Training: Compliance training tends to be delinquency-focused. The trainee is cast as someone about to commit a compliance mistake or misconduct.
  2. Passive Learning: Training is often passive and not experiential.
  3. Isolated Learning: Training is an isolated affair with little social interaction.
  4. Lack of Playfulness: Training is rigid and not playful.

One of the themes that will overlay all these podcasts is effectiveness. As far back as the original Evaluation of Corporate Compliance Programs in 2017, the Department of Justice (DOJ) said training should be adequate. How can we get companies to move off the check-the-box mentality so that they can enhance the user experience through some of the strategies I hope to explore throughout this series?

Four Strategies for Effective Training

  1. Strength-Based Training: Focus on employees’ strengths and capabilities. Training should engage people as effective partners in producing ethical outcomes and creating a more ethical organizational culture.
  2. Experiential Learning: Effective learning is experiential. It challenges people to bring their creative and problem-solving capabilities to the learning situations, think creatively, and address meaningful problems.
  3. Social Learning: Collaborative learning has unique benefits. Ethics training succeeds or fails between people. Effective ethics training should encourage communication and collaboration among employees.
  4. Playful Learning: Make ethics learning more playful. Engaging in play makes us much more deeply engaged and open to new information. Playful learning helps retain information and transfer learned information or skills to different scenarios.

In this blog post series, I will detail the several barriers to effective training, including training being seen as a checkbox exercise, the deficit-focused nature, passive learning methods, isolation, and a lack of playfulness. I will also detail the promising findings that training can be effective when it delivers a positive user experience, emphasizing the need for innovative approaches to improve engagement and behavioral impact. This blog post series explores solutions and strategies for making E&C training more engaging and effective, grounded in four proven learning design principles.

Tune in tomorrow, when I will explore strength-based training and how focusing on strengths can transform compliance training and engagement.

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31 Days to More Effective Compliance Programs

One Month to More Effective Compliance Through Innovation: Day 6 – Future of Compliance Training

Where is compliance training headed? In the 2020 Update, the DOJ stated, “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.” While this tactical solution has proven useful, I wanted to consider the broader compliance training themes that compliance professionals have learned over the past few years to gain insight into where compliance training may be headed. I sat down with Shawn Rogers, Senior Director, Global Ethics & Compliance at Stanley Black & Decker, Inc., to provide some thoughts on the veiled land of the future of compliance training.

Compliance training needs to get to the point where managers and leaders drive compliance training based on how they perceive the risks in their organizations. In other words, an awareness of risks can permeate the organization to such a degree that managers will be able to recognize when their employees need training and can call on the compliance function to provide custom training opportunities.

Three key takeaways:

  1. Business crises almost always begin with a culture failure.
  2. Focus your most detailed training on those employees who are truly high-risk.
  3. This is the “just-in-time” training model that provides training exactly when and where the employee needs the information.

For more information, check out The Compliance Handbook, 4th edition, here.

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31 Days to More Effective Compliance Programs

One Month to More Effective Written Standards: Day 6 – Operationalization of your Code of Conduct

How can you work to operationalize your Code of Conduct as articulated in the DOJ 2023 Evaluation of Corporate Compliance Programs (ECCP)? The 2023 ECCP focuses not on whether a company has a paper compliance program but whether a company is actually doing compliance. A company does compliance by moving it into the functional business units as a part of an overall business process. That is what makes a compliance program effective at the business level. There are several different parts of the 2023 ECCP that touch upon your Code of Conduct.
The Code of Conduct design and implementation process enshrine your company’s values. Those are set by senior management and their input and support for any code project, whether initial draft or update, is critical. This gets to the heart of operationalization and demonstrates how a Code of Conduct can work to meet the DOJ requirements. As an early part of your design and drafting process, you should assemble a cross-functional team. This is important for several reasons. First, diversity in your team will help produce a more well-rounded final product. But having such team diversity will also assist in your benchmarking effort, coupled with those who are going to help you out looking at designs and maybe helping forge the design of the code. Finally, you can use a group to help in the drafting, redrafting and editing process. This diversity will help you to answer all of the DOJ questions from the 2019 Guidance in a manner consistent to support operationalization.
All of these requirements point to getting out and making your Code of Conduct a part of the very fabric of your organization. By using some or all of these strategies, you will have a good starting point. But it is more than simply rollout and training. There must be ongoing communications as well.

Three key takeaways:

  1. What has been the role of senior management in the creation or update of your Code of Conduct?
  2. How have you worked with employees outside the compliance function to lay the groundwork for fully operationalizing your Code of Conduct?
  3. How have you measured the effectiveness of your Code of Conduct training?

For more information, check out The Compliance Handbook, 4th edition, here.

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31 Days to More Effective Compliance Programs

One Month to More Effective Written Standards: Day 5 – Training on your Code of Conduct

What about the training on your finalized Code of Conduct? While there have been criticisms of code training, if you consider training as one source of your 360-degrees of compliance communications, the rollout of a new or updated code can be an opportunity. This rollout fits directly into the concept of 360-degrees of compliance communications as rollout is part of both communications and engagement. The delivery of a Code of Conduct is a key element of its effectiveness. By allowing your employees and other stakeholders to engage and interact with the code, through live or interactive training, the effectiveness can be better monitored and measured.
Beginning with the DOJ’s 2017 Evaluation and continuing into the 2023 ECCP, is the DOJ’s emphasis in the effectiveness of training. I think everyone would understand you do need to train but now the government’s talking to us about effective training. Begin with live training that can be held at the corporate headquarters with senior management and executive involvement. Many companies will videotape a message from the CEO to help celebrate the rollout. Then there is the opportunity for localized training that gives employees an opportunity to see, meet, and speak directly with a compliance officer, not an insignificant dynamic in the corporate environment. Such personal training also sends a strong message of commitment to the Code of Conduct. It gives employees the opportunity to interact with the compliance officer by asking questions which are relevant to markets and locations outside the corporate office, which can often provide employees with the opportunity to have confidential in-person discussions.
However, your Code of Conduct training should be an extension of the way you communicate compliance in your organization. If it is divorced from your 360-degrees of compliance communications style, you may well be missing an opportunity to drive better understanding of the code and denigrate the effectiveness of the training. Whatever approach is used, one of the critical factors is the length of time of the training session. Although lawyers and ethics and compliance professionals can (sometimes) sit through a multi-hour Code of Conduct lesson, it is almost impossible to keep the attention of business and operations employees for such a length of time. The presentation and number of PowerPoint slides must be kept to a manageable length before the attendee’s eyes start to glaze over.

 Three key takeaways:

  1. Consider a video message from your CEO to help roll out your Code of Conduct initiation or update.
  2. Tailor your Code of Conduct training to your workforce.
  3. Consider interactive and modular approaches to Code of Conduct training.

For more information, check out The Compliance Handbook, 4th edition, here.

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Principled Podcast

Principled Podcast – S9 E15 – The Key to Effective Training and Communications? Simplicity.

What you’ll learn on this podcast episode

Building a winning culture of ethics and compliance requires efficiency and effectiveness in all aspects of a program—including training, communications, and a code and conduct. But how do you ensure these elements all work together to create a meaningful and intentional learning experience? While also contributing to desired business outcomes? In this episode of LRN’s Principled Podcast, host Carolyn Grace explores why a deep understanding of curriculum design is essential to developing an effective program. Listen in as she speaks with Erick Sawyer, the chief ethics and compliance officer of Inhabit, (recently rebranded from Inhabit IQ), and Damien DeBarra, the leader of Curriculum Design and Communication Strategy in LRN’s Advisory group, about the learning curriculum they created by leveraging Inhabit’s code of conduct. 

Guest: Erick Sawyer

Erick Sawyer – Grayscale

As Inhabit’s chief ethics and compliance officer, Erick Sawyer leads the company’s day-to-day compliance operations to ensure Inhabit is in compliance with various regulatory requirements and employees are in adherence with internal procedures and policies. Erick creates strategic programs that are paired with tactical plans to positively impact customers and employees across the software ecosystem. Prior to joining Inhabit, Erick held various roles in legal, compliance, quality, and learning and development in the financial services industry. He has focused his career on bridging the gap between people and process to drive a culture of ethics and compliance, protecting the brand and reputation of leading organizations.

Guest: Damien DeBarra

Damien DeBarra – Grayscale

Damien DeBarra brings more than 20 years’ experience to the instructional design and strategic workforce planning spaces.  As the Leader in Curriculum Design and Communication Strategy at LRN, he focuses on creating training solutions that ensure business buy-in and connect hiring practices to day-one learning roll-outs. In the last few years, Damien has helped organizations such as United Airlines, Sun Life Financial, SITEL, Astellas, MFS Investments, and SAP create 90-day action plans for their solutions and develop supporting communication strategies. He has worked with over 200 clients in areas ranging from retail to pharmaceuticals, call centers to nuclear plant manufacturing. Prior to LRN, Damien spent more than nine years as the Learning Solutions Director and Head of Instructional Design at Interactive Services. He has also worked as an instructional designer at NCALT, Electric Paper, and Epic. Damien received his BA from Maynooth University.

Host: Carolyn Grace

Carolyn_Grace_Principled_Podcast

Carolyn Grace is a content writer on LRN’s global marketing team and co-producer of the Principled Podcast. She specializes in writing compelling stories about ethics and compliance that resonate across business segments, industries, and personas while hitting critical KPIs for traffic and engagement. Topics she frequently covers include ESG, data privacy and protection, DEI, the role of boards of directors and leadership, corporate training and e-learning, and ethical corporate culture.

Prior to joining LRN, Carolyn was a writer and content strategist at Thinkso Creative, a boutique creative agency in New York City. At Thinkso, she wrote internal and external communications for clients in technology, nonprofit, law, logistics, and financial services sectors. Before that, Carolyn conducted trend research and cultural strategy at Horizon Media, specializing in entertainment, travel, media and technology, health and wellness, and food and beverage categories. Carolyn graduated magna cum laude from the University of Pennsylvania with a B.A. in American History and French Studies and a minor in Journalism.

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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.
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Creativity and Compliance

The Halo Effect

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 award-winning Compliance Podcast Network.

Ronnie’s company, Learnings and Entertainment, utilizes the entertainment devices that people use to consume information in their everyday, non-work lives, and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies and resources more accessible.

In this episode, Tom and Ronnie discuss the Halo Effect and its role in compliance communications.

Highlights include:

  • What is the importance of making training and comms shorter? What makes it more entertaining, stickier, and helps compliance professionals get increased airtime and exposure, with their messages carried forward.
  • The Halo Effect, which is that people are left with a positive impression.
  • The Halo Effect is not a residual benefit…it is the benefit!
  • The opposite of the Halo Effect is called the Horn Effect…which is that people are left with a negative impression. Hello Compliance!
  • Your compliance reputation doe matter.
  • In every interaction compliance professionals have with employees and leaders, think about Halo’s and not Horns!
  • Maya Angelo once said, people won’t remember what you say, but they’ll remember how you made them feel.

Resources:

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Creativity and Compliance

Training Jams – Using Music to Communicate E&C

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.

Ronnie’s company, Learnings and Entertainment, utilizes people’s entertainment devices to consume information in their everyday, non-work lives and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies, and resources more accessible.

In this episode, Tom and Ronnie discuss a great new series of offerings by L&E, entitled ‘E&C Training Jams.’ E&C Training Jams are an offering by L&E using music as a non-traditional way to communicate with your employees and to build an overall culture of compliance in your organization. In Training Jams, a soulful singer banters about ethics & compliance, explaining policies, sharing examples, and debunking excuses. Ronnie goes so far as to say about E&C Training Jams, “quite frankly, the coolest thing that I’ve ever made because the music gets stuck in your head, and they leave you with a smile.”

Resources:

Check out  Ronnie Feldman on LinkedIn

Check out Learnings & Entertainments on LinkedIn

Follow Ronnie Feldman on Twitter

Learnings & Entertainments 

 L&E Offerings-E&C Training Jams

E&C Jams Sizzle Reel

E&C Jams Promo Reel Landing page

E&C Jams Web Page

Categories
Corruption, Crime and Compliance

Episode 251 – Training and Corporate Culture: Interview of Maria D’Avanzo, Chief Evangelist Officer, Traliant

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Does compliance training have to be boring? Our guest explains how your organization can make compliance training engaging and fun for your employees.

Maria D’Avanzo is the Chief Evangelist Officer at Traliant. Maria provides key insights on corporate ethics and compliance training programs. Maria describes how to take your training program to the next level and tailor the content to deliver training on important issues based on your company’s risk assessment..