By Douglas Kelly
EverFi Lead Legal Editor
Many large enterprises provide compliance training to their employees. A 2017 report by KPMG provides survey data and analysis of compliance best practices, including employee communication and training. This post pulls out data points that allow us to better evaluate the value of effective online compliance training.
KPMG’s The Compliance Journey (“the Survey”) surveyed organizations across seven industries with compliance teams that run the gamut between fewer than 25 professionals to more than 250. While the survey did not indicate the number of respondents, which impacts the sample size, the range of organizations and departments surveyed indicates a good amount of validity.
Summary of Results
The Survey found that organizations are making “substantial progress” in their ethics and compliance programs, particularly in governance, culture, policies and procedures, and communication and training. But, organizations can do better in compliance monitoring and testing. In addition, CEOs can instill accountability across their organizations by considering adherence to compliance policies and procedures as a factor in employees’ performance ratings and compensation.
And sure, compliance scandals have rocked sophisticated companies over the past couple of years. But these setbacks shouldn’t prevent companies from trying to do better to ensure that their compliance programs are fulfilling their goals of keeping companies and, most importantly, employees safe.
Compliance Training Used, But Not Maximized
The report provided specific stats on training and communication in particular. Virtually all organizations (98%) require employees to take compliance training on key compliance policies and procedures and most (84%) train about applicable key laws, rules, and regulations. Companies have realized the importance of training, and implement it consistently across the board.
Yet, it is apparent that companies are not fully utilizing training. Many survey results provide opportunities that good training can accomplish. For example, only
- 31% of Chief Compliance Officers (CCOs) do not know, or do not communicate, lessons of conduct and culture across their organizations
- 29% of organizations report that they assess compliance skills of their staff on an ongoing basis
- 23% do not engage in open communication about compliance issues, lessons, and practices (or do not know if they have such an approach)
- 69% say their organization leverages technology to support its compliance initiatives
Training is a vehicle to communicate lessons of conduct, culture, compliance, and to assess skill building. Online compliance training allows it to be implemented across the entire company and leveraged for data.
Training Best Practices
If training was as simple as just providing it, we would see immediate results. It doesn’t work that way. Understanding does not signify learning or action. In the land of compliance, research shows that merely presenting a law or policy to a learner is ineffective. In fact, it can make people more likely to violate compliance standards. This may be why “CCOs recognize that adult cognitive learning theories support offering shorter trainings that are more memorable, engaging, and that contain real-life vignettes.” Engagement is important to learning, but again, it’s not enough. To learn more about effective adult learning theory, check out EverFi’s white paper, Value of Conduct Training.
Fortunately, the Survey provides many examples of how companies, or their training vendors, can make compliance training more effective. Here are some highlights.
- Identify what needs to be trained on based on internal risk assessments
- Use storytelling, “refreshers,” and real examples from the company’s workplace
- Train middle managers to “enhance accountability” and “develop ethical leadership skills”
- Deliver “compliance training content to employees who may historically only been
reachable via live/in-person training using advances in technology” - Leverage technology to monitor and follow up on the results of regulatory testing
- Utilize technology to “track training results and content distributed to employees, as well as to enable more targeted training for employees based upon their roles and responsibilities”
Indeed, when asked about their top compliance challenges, CCOs responded that enhancing accountability in compliance, improving data quality, and making compliance effective and sustainable were the top three. Online compliance training, when developed effectively and rolled out to a willing audience, can help organizations meet their biggest compliance challenges.
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