In this episode of Excellence in Training, Shawn Rogers provides some thoughts on the veiled land of –the future of compliance training.
- I Hope Compliance Training will be More Respectful of the Learner
Compliance training needs to evolve to be more respectful of the user’s time and intellect. I hope that compliance training will become much less repetitive and that companies will figure out ways to give learners credit for the training they have taken in the past.
No other training discipline that makes the learner take mandatory training on the same learning objectives year over year. Rather than giving the learners credit for understanding and internalizing and applying the training they have received in the past; they keep repeating the same learning objectives. To eliminate the monotony, they try to take different approaches, such as gamification, videos, virtual reality, etc., but in the final analysis, they are still teaching the same basic learning objectives.
Embrace the concept of teach once (maybe twice) and then remind frequently. Over-training is a waste of both company resources and employee time. If we could accurately measure scrap learning rates, there could well be incredibly high in most compliance training programs.
- I Hope “Compliance Training Abuse” will Stop
By “training abuse,” Rogers’ mean the tendency of companies and government officials/agencies to apply/require training courses/programs to problems that training can’t and won’t solve – but instead gives the illusion that “something is being done.”
In the United States, many state governments are requiring companies to implement anti-harassment training, and repeat it every year (e.g., New York) or every other year (e.g., California). There are only so many ways you can train people on anti-harassment, and only so many learning objectives associated with anti-harassment. Yet, in some jurisdictions, companies have to provide annual training to employees, not because the training will change anything when done for the fifth or tenth time, but because it is required by the force of law. This becomes another form of tax on the company, it annoys and frustrates the learners, and it undermines carefully thought-out training strategies.
When a company is hit by a major scandal, often the first response is “we will require training.” This decision is typically motivated by a desire to send a signal that the company recognizes it has a problem and that it’s going to train people into behaving properly. Well, Rogers believes that 98% of problems a company face are caused by about 2% of its employee population. So, for 98% of the employees, the training becomes punitive rather than helpful, and the 2% of the bad actors ignore it. But there has been an illusion created that the company is taking steps to fix the problem, and it gets headlines and publicity. And the masses are pacified.
- I Hope Compliance Training will become More Relevant to Learner Roles
There are some ethics and compliance topics that every employee in a company needs to know at an awareness level. For example, every employee needs to know that the company has a code of conduct, where to find it, and what it contains. Every employee needs to know about the company’s hotline and how to report issues. Every employee needs to know about the company’s non-retaliation policy and the protections it provides. Every employee needs to be aware of safety policies and procedures.
However, when it comes to some of the more serious legal and regulatory risks, not every employee has the same level of risk exposure. Take bribery, for example. Most employees need to know the company’s position on bribery and that the company has a policy. These employees need understanding at an awareness level, not at a highly technical level. However, there are some employees that are in a position to either offer bribes or be bribed because of their job function or their location. These employees need in-depth training on how to handle these situations.
Hopefully, as a compliance profession, will become more adept at providing training that is adapted and tailored to the risk that specific individuals or groups of individuals present to the company and to themselves. This could be accomplished by better profiling learners through HR data, by using “adaptive” online training, and by focused training campaigns to high-risk audiences.
- I Hope Compliance Training becomes More Integrated into Business Processes
This is the “just-in-time” training model. It is one thing to have an annual compliance training requirement, and quite another thing to provide training exactly when and where the employee needs the information. For example, many companies provide insider trading training as part of annual training requirements. Then, they hope the employee remembers the principles when he/she decides to buy/sell the company stock.
But wouldn’t it be better to include some kind of “micro training” or policy reminder at specific times when and where the risk is highest? Perhaps certain groups are more prone to being aware of insider information – they should get frequent and targeted reminders. Perhaps the company has “trading windows” after earnings announcements. When the emails go out to the company that talk about the authorized trading windows, perhaps that’s a good time to provide an embedded training module.
Another example is when an employee is traveling overseas and might be carrying company samples or might have a computer that contains sensitive company data. That would be a great point to embed a “hand carry” training module or a trade controls training module into the travel booking process.
- I Hope Compliance Training becomes More “Bottom-Up” Driven than “Top Down” Driven
Rogers hopes that compliance training can get to the point where managers and people leaders drive compliance training based on how they perceive the risks in their organizations. In other words, I hope that awareness of risks can permeate the organization to such a degree that managers will be able to recognize when their employees need training and can call on the compliance function to provide custom training opportunities.
Rogers ended by noting he would like to see managers become more empowered with the tools they need to be better partners with the compliance function. This is happening to some extent, but it needs to happen more. For example, at GM we recently installed a new leader for our Korea operations. One of the first things he did was to request compliance training for the senior leadership and all people leaders. He suggested both the topics and the approach to the training. He wants to see this happening more across the company.
Disclaimer-As a company, GM uses many training vendors. GM’s compliance function primarily uses two vendors. Rogers has worked with other good vendors that currently do not work with GM. Rogers is not promoting any specific vendors, nor is he disparaging any specific vendors in this podcast. And, of course, these opinions are Roger’s alone and opinions that developed over almost 15 years. He is not speaking on behalf of GM in any way.