Training takes a large slice of of most companies compliance budgets, anything from a quarter to a half. So is it effective? 
Measuring training effectiveness remains a weakness of many L&D programmes and compliance and ethical training seems no different. However, the escalating cost of compliance work is worrying senior managers. Many see the present situation as a black hole into which resources keep being relentless absorbed.
To make more sense of training for compliance it is only a matter of time before those charged with promoting an ethical culture will expect to see a) an explicit budget for any compliance training investment, b) clear criteria for assessing its effectiveness, and c) evidence the resulting training actually delivers.
Currently, the main way of judging the effectiveness of compliance learning programmes is by completion rates. In one US study for example nearly one in four responders said this was the way “they measured effectiveness in training,”
Completion though is a poor way on which to judge training, let alone compliance and ethical awareness. It’s not much better, in fact, than the largely discredited happy sheets that still prevail in so many places purporting to deliver learning and development. .
This particular kind of training investment needs evidence of resulting changes in behaviour. Handing out a code of conduct and obtaining a signed acknowledgment that an employee has read it for example, is not training.
But compliance in the broadest sense of meeting corporate goals of ethical performance is rather different. Here the formal rules keep changing, almost daily. Even the experts have a hard time keeping up.
For the average employee, compliance training tends to be minimal, lasting just a few hours and usually with a strong focus on the minutiae of codes and rules.
This sort of “training” is almost bound to fail. Effectiveness here means people absorb the essential ethical message: “in this organisation these are our values, we make them stick and we want you to live by them.”
So what is proper evaluation?
As a minimum, evaluation of compliance learning means conducting an audit to ensure employees really do grasp the organization’s ethical climate. This involves checking whether they’re comfortable reporting potential violations of the organization’s policies or the law, discovering how they view the organization’s commitment to compliance, and extracting from them whether there are risks the program is failing to address.
As a result of the learning for example, evaluators may need to ask: “is there more use of hot and help lines; are supervisors facing more questions about compliance and ethical issues, do people feel more confident speaking out about possible ethical abuses; are they comfortable talking to a compliance officer about ethical concerns that may arise?”
More specifically, the learning must translate into improved ethical conduct and a commitment to compliance within the law. Longer-term there must be credible evidence that actual ethical abuses and wrong doing are being actively tackled, and in some cases reducing–even when these cannot be directly attribute to a specific set of learning events.
An important aspect of evaluating any compliance or ethical training, is recognising it’s essentially about achieving a cultural shift. Naturally there must still be the basics—such as regular training dealing with sexual harassment, discrimination, bullying, safety and so on.
Here are five essentials for ensuring ethics training delivers the goods
No one is immune.
Everybody in the organisation must go through the ethics and compliance learning programme, regardless of the position in the hierarchy. Maintain rigorous checks to make sure no one is immune.
In one University for example, a lecturer kept avoiding the ethics training year after year, until it became a standing joke. He was eventually confronted and told—“attend or resign.”
Dov Charney, the notorious CEO fired recently from American Apparel was allowed to simply refuse to take sexual harassment training mandated by law. He violated the company’s Code of Ethics by continually disrespecting employees with derogatory remarks. Had he taken the anti-harassment training he might have learned something and still be in his job.
Prioritise values, culture and the “other stuff”.
It’s vital compliance and ethical training deals with mission, vision and values—that is the culture of the organisation. There must be the “other stuff”, offering practical guidance on where the lines are drawn for practical everyday situations.
In particular supervisors and middle managers must be seen to be comfortable talking regularly with their people about values and “the way we do things round here”. In some organisation this process is now built into regular team meetings, and scheduled interactive sessions dealing with ethical dilemmas people may encounter in their work.
Build awareness and communication campaigns
This starts with “tone from the top”, that is, a steady communication diet from senior leadership about their wish to run a responsible organisation, where “doing what’s right” comes naturally.
Just as it would be wrong to rely on training alone to deliver compliance and ethical awareness, so it would be misguided to assume an awareness and communication campaign is all that is really needed.
Senior management often have an exaggerated view of their own effectiveness at communicating and influencing employees. But in practice the unspoken message back from employees is: “Just because you’ve said it, doesn’t mean we’ll do it!”
Throughout the year there should be ongoing awareness campaigns which need not been excessively time consuming. For example, some of the excellent and funny compliance videos from Second City about ethical awareness can be both entertaining and stimulating.
Similarly posters, emails, and regular messages from the leadership can help re-enforce training in many useful ways.
Use interactivity to bring to life issues that might impact employees’ work life.
Realistic scenarios, simulations and well constructed games can help employees relate to actual policies and see how these might affect their working life. Usually these should involve people actually speaking with people, not sitting at a computer and pressing keys.
Build ethical behaviour into normal performance appraisals
Samuel Johnson of English dictionary fame, famously remarked “when a man knows he’s about to be hanged-..it concentrates his mind wonderfully.”
Something similar applies to achieving an impact with ethical and compliance training. When employees know they’ll be judged regularly on how far they’ve absorbed the ethics messages and whether they’ve put them into practice, the result is likely to promote improved behavioural change.
Since most practising managers hate doing performance reviews the best approach is to expect managers to assess performance both informally and regularly, rather than the once or twice yearly appraisal process.
Managers need to systematically look for evidence the ethical and compliance training is working, that employees can demonstrate its messages are getting through.
If compliance training is really to be effective it must become more than an exercise in creating rule awareness. Instead, it should be the foundation of an organisation’s ethical culture. That is, an ongoing process of continuous education, protecting its reputation and re-enforcing its values.
Such a programme is not a drain on costs, so much as a crucial investment in the organisation’s long term survival. It is not an optional extra, it’s a way of life.
1 See for example:
E. Olaoye and S. Gittleman, Effective training a weak link in many compliance programs – survey, August 13, 2014
The 4 Lever Formula: Elevating Your Compliance Training Effectiveness, CEB (60 mins)