Many companies default to the most basic form of training: some off-the-shelf e-learning modules, purchased from one of the well-known compliance vendors. This is certainly the most basic form of training and the easiest to implement. It is simply a matter of paying a license fee and connecting users to a learning management system (either your own or one hosted by the vendor). However, many of these traditional courses started out as training modules for lawyers and are therefore too legalistic: they contain myriad references to legal words and maxims, list the names of relevant legislation, and even mention sections and case law.
There are a number of basic things that people can do to fix this situation.
Re-evaluate the courseware
Take a good hard look at the courseware. If it is off-the-shelf and pre-built, then it is probably not ideal for you. If you are working for a large company, then, frankly, the company can afford to have custom-developed courseware. Indeed, financial models and total cost of ownership suggest that you will be better off developing it yourself, owning the IP and controlling your destiny. This doesn’t mean you have to now be a course designer as well as a compliance officer – you can outsource that – but you decide the content.
Seriously consider in-person training
Over the years in-person training has been overlooked as it was considered too expensive or just not practical. These are historically fair comments; however, with the focus on compliance and the amount of fines and expectations of stakeholders, regulators and even employees, the answer that ‘It’s all too hard and expensive’ is no longer good enough. In-person training with an experienced, knowledgeable facilitator teaching interactively to a small group is clearly the best solution. A good compliance programme must have a strong element of in-person training. These should be facilitated workshops, and PowerPoint presentations must be banned. Training should be exactly that – not summaries of issues in slides. Trainees should be given real-life and hypothetical scenarios and challenging tasks involving ethics and decision making. The effectiveness of the training should be judged by the effect it has on managing risk and reducing exposure. This may require the compliance manager to really think about how to engage the business in doing some of the training themselves.
Find a presenter
If you are not an engaging speaker that can run a facilitated workshop to an expert degree while keeping people engaged and having fun while they learn, then you must employ someone that can. Simply understanding the content does not make you a great trainer. Historically, the view was that only lawyers could conduct compliance training. This view presupposes that the content is just so complicated that it requires a lawyer to teach it. Again, this is a flawed view: if you required the expert skills of a lawyer to teach compliance training because it is based on laws, then wouldn’t lawyers also be required to teach people how to drive, as that is based on traffic laws?
Set a curriculum
You need to have a curriculum for all employees: actually identify what they need to learn and determine the best way of teaching each group. For example, sales people will never learn from e-learning – they are ‘people people’ and learn best in simulations and small groups. You need to give some real thought to the curriculum. This is too often overlooked because it is easy to make everyone do the same courses, as dictated by the learning management system software.
Make the business present
If you do not choose to engage a presenter, as above, then get the business teams to present. Get the country manager or the regional business general manager to not only introduce the training, but actually lead it. If they couldn’t be bothered or you don’t feel confident in their ability, find another regional manager or general manager. It should be very easy for a regional manager or general manager of a multinational corporation to be able to handle this sort of interactive training; if they can’t then you need to seriously look at the leadership team from a skillset perspective.
Make it relevant
This sounds obvious, but what is relevant to a finance person is different to what is relevant for a support engineer, which is different again to what is relevant for a sales person. Rather than do three or more training sessions in a country or office to cover the population, perhaps consider specific training for specific groups (for example, training finance people on bribery and corruption, and training sales people on bribery and corruption as well as anti-trust and handling confidential information). If you make the training specific to the people you can make it more relevant and keep them engaged. Talking to people about ‘gifts to government officials’ when they never see government officials and would never find themselves even contemplating giving a gift is a waste of an example and a waste of their time. Focus on giving relevant content and examples.
Examples of targeted anti-corruption training
For finance teams
- Books and records violations
- How to find incorrectly-described or hidden expenses
- Caution around government official office audits and tax filings and investigations
- Use of intermediaries for office approvals and utility connections
For human resources teams
- Accepting gifts from recruitment agencies
- Using recruiters that charge applicants for interviews
For legal teams
- Caution on using ‘local’ lawyers to get difficult government approvals
- Use of private investigators to conduct investigations or due diligence
For marketing teams
- Caution around use of travel agents for corporate events
- Using PR companies and holding press conferences and reimbursing expenses
- Giveaways for sales
For sales teams
- Gifts and entertainment
- Giveaways for clients
- Travel for clients to corporate events
- Special discounts for resellers
- Use of unauthorised resellers or other contractors or third parties
- Side letters around contracts