Eating the Elephant – Planning an Ethics & Compliance Curriculum


Recently I facilitated a pre-conference workshop at the Ethics and Compliance Officer Association’s 21st Annual Ethics & Compliance Conference in Chicago that focused on cutting down the sizable job of designing a good education plan into chewable bites. I had two great takeaways from the session that reinforced messages I’ve received from many clients:

  1. The majority of organizations are not experienced with planning a compliance curriculum tailored to various risks, audiences and delivery methods
  2. People are very interested in learning a good planning process

Given the interest, I thought it would be helpful to pen a summary of the good points and the process discussed during the pre-conference.

  • It is not effective from a learning or cost standpoint to deploy all communications and training to all employees, all the time. They will suffer from “education fatigue,” overdosing on some quantity of irrelevant information and being desensitized to information that is directly pertinent to their jobs.
  • A good curriculum plan will calibrate all dimensions of communication and training to fit together in the most effective way. We call this a curriculum map, and help clients create them often.
  • Start your planning by looking at your ethics and compliance risks, which is more than the ERM risk list. The session participants agreed that their biggest risks were reputational.
  • Your top risks should drive the topic list for your curriculum with added subject matter related to your compliance program - such as the helpline and investigation process, resources for reporting and messages to manager regarding their program responsibilities.
  • Group your workforce into “audiences” based on risk exposure and subject relevance. Assign groups to the topics. Some training and communications may be relevant to your entire workforce, including third parties. This is often true with code of conduct training and gift policy memos.  Other education is best targeted to only those people who are routinely exposed to a risk; for example, in-depth anti-corruption training for an international sales force or ethical leadership training for management.
  • Think about how frequently you want to touch each audience with an educational message. Some groups may receive online and instructor-led training plus several extra communications per year on risky topics. By contrast, the “all employee” group may receive code of conduct training and see one or two posters per year that reinforce compliance messages. But do not err on the side of doing too little. Remember, Morgan Stanley famously avoided prosecution for corruption due to its robust education efforts addressing anti-corruption.
  • Next, consider all the methods by which your organization already conducts training and communications.  Keep those that work and think creatively about adding new methods. At NAVEX Global, we know from our hotline/helpline work that posters are the #1 way employees locate the number to call. We also know that audiences have shorter and shorter attention spans. Burst Learning, interactive videos of 5-7 minutes in length, delivers important information quickly. Think about using both what you know works already and what is cutting edge. Mix up your methods for best effect.
  • Determine how you will measure the effectiveness of each educational effort. Will you measure learning with an online survey three months after a training session? Will you look for changes in reported issues in the months after an especially memorable poster is launched? There are many effective ways to measure the impact of your education.
  • Finally, transfer your curriculum map to a calendar and shop it around for internal buy in. You may want to partner with HR or Corporate Communications to produce the materials. And sharing the calendar will keep you and your partners accountable to meeting the deliverables.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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