The General Motors (GM) 2018 Sustainability Report is out. It reports on GM’s progress toward an era of safer, better and more sustainable personal mobility by transforming how General Motors approaches every aspect of its business. But more than simply a report, it is a celebration of the journey GM has been on since its ignition-switch scandal earlier in the decade.

From the compliance perspective, it features Shawn Rogers, who is Lead Counsel, Compliance Training and Communications within the Global Ethics & Compliance Center at GM. Rogers is the co-host with me on Excellence in Training, a podcast where we provide compliance practitioners ideas about training, what works and does not work, and how Rogers been able to develop a best practices and best in class training program at General Motors. The podcast is a production of the Compliance Podcast Network.

In the GM 2018 Sustainability Report, Rogers explained what it takes to create a compliance program that does much more than check a box, but rather builds an ethical culture.

In times of rapid change, it’s tempting to lose focus on something like compliance training. What is GM doing to keep it front and center?

It starts with how we communicate. As far as I know, at other companies there isn’t a position quite like mine, which was created specifically to look at key elements of the compliance program related to training and communications. Another mental shift we’ve made is viewing compliance training as an opportunity to reinforce our ethical culture. If you don’t implement your training program strategically, learners begin to view it as a task that they have to do just to satisfy lawyers. But when we trust that our employees are committed to our Code of Conduct and eager for more information, training programs can become so much more.

How do you go about building a new compliance training program?

It’s important to start with the end in mind. A common mistake is jumping right to tactical questions like which courses you want and how to deploy them. Instead, we chose to begin by drafting design objectives, a set of course standards and a list of the exact risks that we wanted the training program to address. We also came up with three foundational principles that guided our efforts: Trust, Respect and Accountability.

We rely on these principles when we select our vendors, when we decide how many courses should be required each year, when we pick the languages for translations, when we set training completion deadlines, when we send out reminders, when we could grant exceptions and so on.

What is an example of how these principles have shaped training programs?

The principle of Respect refers to the respect we show for employees’ time and intellect. We do this by not requiring employees to take courses that are not relevant to their role, keeping courses short and to the point and setting content standards so that employees don’t have to learn a new method every time they take a new course.

Just as GM employees are united by a shared set of behaviors, our guiding principles have become the measuring stick for our compliance training program. From there, we’ve created a framework for a training program that’s strategic, approachable and flexible enough to accommodate emerging risks and trends.

The GM 2018 Sustainability Report also featured information on the GM Global Ethics and Compliance Center (GECC), which brought forward several challenges to encourage GM employees to live the company’s values. There was a review of employee recognitions submitted during the year for the behavior modeling the motto “Win with Integrity.” The GECC also chose three Integrity Champions after reviewing more than 50 recognition submissions. Each Integrity Champion received 10,000 GM points through the GM Recognition program. GECC also challenged functions to have the most employees complete Corporate Required Training by a certain date. The winning team received a “traveling trophy” that they are allowed to display until the next winner is chosen the following year.

Finally, the GM 2018 Sustainability Report celebrated  GM’s Code of Conduct, Winning with Integrity, as the cornerstone of GM’s compliance program. It not only serves as a statement of GM’s shared values but also is a guide to help employees make decisions that earn loyalty, trust and respect. It applies to everyone in the company at every level.

The Code of Conduct was updated in 2018 with GM’s new company Value: Seek Truth. This was added to GM’s existing Values of Customers, Excellence and Relationships. Seek Truth means GM uses facts and data as a foundation for respectful dialogue that ultimately leads to better, smarter decisions for the business and for our customers. Guided by these values, GM employees are working as one team, building a safer, better and more sustainable future.

This update built upon a redesign of the GM Code from 2017 to include more reader-friendly content, better examples and explanations and supplementary decision trees and graphics. While the core underlying GM policies continue to be reflected in GM Code, it included new subject areas such as cybersecurity and human rights, and provided guidance on many issues, including safety, speaking up and non-retaliation.

The GM 2018 Sustainability Report is to be celebrated by all compliance professionals. Not only did GM specifically cite to Shawn Rogers, recognizing his excellence in designing and implementing a great compliance training program, it celebrated the corporate compliance function and compliance professionals in the organization.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2019

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