By Sunny McCAll, JD, LLM, Director, Compliance Training & Accrediation, TRACE International, Inc.
Gwen Romack, CCEP®, PMP®, SSGB® – Senior Director, Legal & Regulatory Compliance, VMware
Whether you work for a multinational Fortune 500 organization, mid-size regional firm or a budding startup disrupting a market sector, effective compliance training is a must. Impactful and memorable training is a key factor in influencing your company’s culture and compliance while also shielding your organization from legal risk and protecting its reputation. But, truly effective compliance training is a tricky combination of art and science. Despite the universal yearning for that secret recipe, the magic often results from a careful manipulation of both form and function. If you put 10 top chefs in the same room with the same ingredients and goals – think you’d get the same result? Probably not…therein lies the magic. It’s art and science.
Today’s business environment is composed of a globally-based mobile workforce that spans generations. And because nearly all of us have little patience and time for extended (and boring) training courses, it is critical that you think of your employees as consumers to whom you need to carefully target your training. Before building your program be sure you consider the following:
• Who is your target audience?
• How is the training relevant to the employee and their day to day jobs?
• What is the risk to the employee personally and the business for non-compliance?
• Why should the learner care about mitigating the risk?
Identify your target audience – A standard template may work for the masses, but when you want to drill down to certain regions, hone in on specific subject matter areas or employee demographics, the basic recipe just won’t work. Consider the top chef analogy – you will be serving a meal to a diverse group of critics, half of whom you know are under the age of 35. That tried and true baked chicken dish may always be a winner but it is 2018 after all. You’ll need to account for those who are vegan, vegetarian or just prefer not to eat meat. The basic premise of the recipe is still solid but you’ll need to sub out the protein – same recipe, different ingredients. For your millennial workforce, possibly you’ll need to distill your bribery training down to a short, scenario-based vignette. Make it interactive and pithy, using true to real-life scenarios, gamification and animation. Same recipe, different ingredients. Art and science.
Make the training relevant to the employee and their day to day – indeed your basic, 3-course meal plan is solid, never receives a complaint but…this meal was billed as an exclusive eating experience for a select group of critics. You’ll need to sub out vegetable oil for truffle oil on the fries, surprise their palate with the use of an exotic vegetable in the main dish, wow them with a flourless cake for dessert. Drawing the comparison to compliance training, be sure you know what subtleties you need to be aware of to be most effective with various local workforces. Hone in on an issue that is a pain point for the locality you will be training. Make it practical. Speak in terms they can relate to, utilize true-to-life scenarios that will provide useful guidance making their day-to-day jobs easier while ensuring compliance with company policies. Pay attention to the subtleties, but don’t get lost in them. Art and science.
Identify the risk to the employee personally and the business as a whole for non-compliance – Your flourless cake is indeed delicious – anticipated even. Everyone will want to select it from the menu. Smartly, you choose to only bake 90, 10 unlucky guests will have crème brulee. When building out your training course, stress both the personal risk to the employee and the business overall if company procedures are not followed. Highlight in your training recent examples of when employees strayed from policy, balanced with recommendations and acknowledgements for great work by internal compliance champions. Complete your training on-time and with a passing score, a certificate is awarded. Complete your training late or not at all, you’ll need to spend time re-doing your resume. Ensure your employees know to get one of the flourless cakes.
Lastly, find a way to help the learners personally connect or invest in the value of mitigating the risk and complying with the policies. Connect the issue to the broader company mission or whenever possible, the real-world implications. Corruption redirects money away from critical health, safety and welfare programs that citizens in some countries literally require to survive. Human trafficking and modern-day slavery is a very real epidemic. When possible, connect the learner to the reason behind the policy or regulation. There’s often a compelling narrative to consider.
Ideally, your training program will reduce risk, raise awareness and reinforce compliance.
The words fun, engaging and succinct are not mutually exclusive to the compliance training. You can have the best of both worlds. Just remember it’s art and science.
Sunny has worked at the intersection of regulation, compliance, market trends and business for the past decade. As Director, Compliance Training & Accreditation, Sunny oversees both the training and the TASA Accreditation Program: TRACE’s Anti-Bribery Specialist Accreditation®, the only accreditation program of its kind, exclusively dedicated to anti-bribery compliance.
Gwen Romack is the Senior Director of Legal & Regulatory Compliance for VMware. This includes the development and execution of a new Legal & Regulatory Compliance structure for the company.