How can you begin to think through a best practices compliance training program? I put that question to Shawn Rogers, Senior Director, Global Training & Awareness, Walmart. Rogers advised that you ‘envision’ what your training would like as a first step. He stated, “A common mistake is jumping right to the question is which courses you want and how to deploy them. However, there are several things you need to think about before you start building the program.”
You should develop some principles on what your compliance training will look like. A key way to start is by reference to the Training and Communications section of the 2020 Update, which stated, “Prosecutors should assess the steps taken by the company to ensure that policies and procedures have been integrated into the organization, including through periodic training and certification for all directors, officers, relevant employees, and, where appropriate, agents and business partners. Prosecutors should also assess whether the company has relayed information in a manner tailored to the audience’s size, sophistication, or subject matter expertise. Some companies, for instance, give employees practical advice or case studies to address real-life scenarios, and/or guidance on how to obtain ethics advice on a case-by-case basis as needs arise.” Some of these principals include the following,
What are the Guiding Principles of your compliance training? What are you trying to communicate? Is it a broad set of values you want to communicate to every employee about what your organization stands for? As noted in the 2020 Update, a company should “should examine whether the compliance program is being disseminated to, and understood by, employees in practice in order to decide whether the compliance program is “truly effective.”
Three key takeaways:
- The 2020 Update has a strong emphasis on compliance training.
- Create a set of Principles for your compliance training programs.
- You should always use the Principle of your compliance training program in making decisions going forward.