By Joe Murphy
From Compliance & Ethics Professional, a magazine for SCCE members.
Training is a core part of any compliance program. How can people follow the rules if they don’t know what the rules are? We also know that training needs to have a real impact if it is going to affect what people do. We can use many tools, bring in the best trainers, use the best techniques for adult learning, and even mix in the use of drama through online media. Even with these excellent methods what happens after the training? The employee goes back to the normal world of work, and all the job requirements, pressures, and urgent messages are there to grab his or her focus. Even for the best training, how much impact is there a week or two later?
Consider another fact in this picture. The most important influencer in an employee’s work life is the immediate boss. Sure, the CEO may set the tone at the top, but for those who don’t live at the top, the immediate supervisor is the most important person in the company.
So let’s consider how to put these two points together. Of course one could have supervisors do the training. I deal with high-risk, technical areas like anti-trust and foreign corruption. It may work having supervisors cover topics like values and ethics, but I strongly recommend not leaving topics subject to criminal penalties to amateur instructors. There are too many things that can go wrong. Moreover the supervisor may not have the training expertise to deliver the content effectively. But you can get the best of both worlds.
After your initial training, you can extend the life of the message by making it the supervisors’ job to have renewal sessions with their subordinates. For example, two weeks after the anti-trust training, have the sales manager call the salespeople into the office and ask each one what he or she remembers from the training. What important lessons were there? How has the employee changed what he or she is doing, and why is this important? The supervisor would also make it clear that these things matter to the supervisor and will be considered in employees’ annual assessments. The supervisors could be given a “how-to” guide for these renewal sessions.
What would motivate supervisors to do this? Make it part of their formal job description and, most importantly, part of their annual assessments. This gives you a way to use incentives (as required under the Sentencing Guidelines and other compliance program standards) and helps ensure that the renewals will actually happen.
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