Returning to the theme of profound grasps of the obvious, compliance officers face numerous challenges where they need creativity and persistence. One area which is not as hard as others is training. A good training program requires common sense.
Here is the rocket-science question – How do you make your training program interesting? Well, the Justice Department and SEC’s FCPA Guidance provided a little bit of a clue – they suggested that the presentations should be audience-specific. That is more than a good idea. It is plain old common sense.
There is more to the question, however. How does a company make sure that the audience will listen and understand the message? It has to be relevant to the audience’s day-to-day activities. Starting with this point, let’s look at the components of an effective training program.
First, a company’s training program needs to have a mix of on-line and live training sessions. Live training is the most productive way to conduct training but is the most time consuming and costly since it usually requires travel by compliance staff.
One way to leverage the limited resources and promote the company’s commitment to compliance is to consider training senior executives to conduct compliance training programs and having them conduct live sessions when they travel to various areas. The benefit of such a “cascading” program is it sends a message when senior executives conduct the training and it stretches the company’s ability to conduct live training programs.
Second, a company has to work closely with vendors to design the content of an online training program or find a vendor which provides a program which is relevant to the audience. Online training packages are readily available but they are not created equal. It is a good idea to review the program carefully and make sure the message fits the need and the audience.
Third, a company should divide its training program by distinct audience categories. The board should be trained. The C-Suite needs to be trained. Senior managers and sales staff need to be trained separately. The professional staff – lawyers, accountants, and human resources should be trained together. Depending on the mix of categories and the risks which each faces, groups should be divided.
It is important to tailor the message to the audience. What are the likely scenarios which come up in their day-to-day business activities? The more real life examples and scenarios which are presented, the greater likelihood that the message will stick. Too many training programs recite lengthy legal slides or the company’s code of conduct and fail to engage the audience.
Most importantly, training is an opportunity to encourage communication and cooperation. The trainers should not engage in fear mongering – we are all past that. Rather, a training program gives the compliance staff an opportunity to demonstrate that they are interested in helping everyone to comply, and to support the business and promote growth of the company. It is helpful to give examples of problem-solving approaches in which compliance was part of the solution, not part of the problem.
Company employees often view the compliance staff as the company’s “sheriff” or law enforcement team. That is not a welcome perception – it can be part of the mix when it comes to enforcing company policies, but it is better to present the compliance office as a business partner, which is dedicated to making sure business operations do not violate company policies or laws, while solving problems and coming up with creative solutions.