While focusing on new tech, disruption, and regulation change, training often gets left behind in the compliance and innovation conversation. To bring training back to the forefront of the conversation is Shawn Rogers, Lead Counsel, Compliance Training and Communications at General Motors who chats with Tom about GM’s innovative training methodology.
- What does General Motors do so differently than other companies? Tom asks Shawn to expand on the most obvious example: the existence of a position like Lead Counsel, Compliance Training and Communications.
- We know why innovation is so important when it comes to strategy, tools, and integration, but why is innovation around compliance training so important? Shawn explains that to keep up with the speed of the digital age, we need to recognize how different learning is today and develop training programs that draw upon the various new ways people use information technologies. Voiced-over slides just don’t cut it anymore.
- For GM, risk-based training is part of the larger work of addressing internal culture issues, but it can be misused or under-used. Shawn talks about how training can end up being a reactionary impulse to specific problems that may require a more coordinated and broader effort; he also talks about how GM views their training programs holistically.
- Tom asks Shawn about GM’s training needs analysis; what is it and how does GM use it in the compliance space? Shawn gives us a detailed insight into his process in developing GM’s compliance training framework at GM since he joined them.
- Shawn’s efforts didn’t exist in a vacuum. Tom asks Shawn about his work in updating GM’s compliance training governance structure and how that has enabled them to build out their new training solutions.
- GM’s training programs have been updated for the information and digital age, but what makes them unique as risk-based and tailored training solutions? Shawn talks about the importance of a) training the right people, b) training them on the right risk, c) getting to the right level of detail, and d) training them in the proper language (linguistic and institutional). He also mentions the importance of training frequency and, notably, modelling realistic risk situations for better preparedness.
- In Shawn’s opinion, off-the-shelf training programs have their limitations and often end up being delivered annually with little custom tailoring. Shawn talks about how the architecture of a truly successful risk-based compliance training program must be appropriately adapted to the risk profile and culture of the company in question.
- GM’s new compliance training architecture is a result of Shawn’s synthesis of a training needs analysis and the company’s specific risk profile. He provides a brief description of the pyramid-shaped, four-layer structure of the program. He also talks about the training methods used at each layer, from in-person group training; to online, adaptive, tailored content; to high-level tailored trainings.
- From broadest to narrowest, the first layer is about general company-wide compliance awareness and protocol. The second is about specific risks, each with their individual courses (anti-corruption, bribery, anti-trust). The third layer is all about situational risk, providing specific training resources for situations that employees may encounter. The top, fourth layer focuses on the highest risks and those exposed to them, using GM’s subject matter experts in live trainings with these small, tailored groups.
- Even with cutting-edge tailoring and content delivery, how do you ensure that your compliance training program is truly effective in the field? Tom mentions the Department of Justice’s focus on the subject and asks Shawn about how GM demonstrates effectiveness in their training programs. Shawn talks about the ultimate catch-22: how do you measure successful preventative efforts?
- When people ask Shawn about why and how his approach to compliance training is effective, he’s got the answer down: GM’s training strategy is overseen by the CCO, it is customized to their constantly updated risk profile, it is tailored to their specific culture, it incorporates the input of best-in-class compliance trainers and instructors, and it ensures their training content is engaging and relevant. It also features strict completion requirements, conducts post-training surveys for continuous improvement, and is generally collaborative.
- For Tom, flexibility in training programs is a key piece of the compliance innovation puzzle. Shawn talks about GM’s philosophy on training flexibility and relays a recent example about the emergency implementation of an anti-harassment course in response to the #MeToo movement.
Shawn Rogers on LinkedIn
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