I am attending the Global Ethics Summit 2010, hosted by Dow Jones and Ethisphere. Here are my notes, live from this session:
Having a code of ethics is not enough to ensure compliance. Training is the vital step that brings these standards to life—effective training helps ensure that key tenets are retained and applied. While organizations need to take every measure to ensure that employees take training principles and apply them to everyday situations, this oftentimes is easier said than done. What are the best practices in workforce training employed by leading organizations and their training providers? What are they training on, who’s being trained, and how is this training being delivered, communicated and tracked?
- Erica Salmon Byrne, Assistant General Counsel & Managing Director, Compliance Advisory Services, Corpedia
- Stella Raymaker, Director, Ethics & Equal Employment Opportunity Compliance, Waste Management
- Loren Becher, Manager, Compliance Training and Communications, American Express
- Howard Sklar, Anti-Corruption Counsel, Hewlett-Packard
Stella pointed out that a large percentage of her workforce is not connected tot he company through electronic messages. There is a difference in how you need to communicate with blue collar and white collar workers. Diversity is not just ethnicity and gender. Twitter is not going to reach everybody in your company.
Loren has a diversity with job functions at American Express. They had an enormous job just cataloging all of the compliance programs throughout her organization. They created a toolkit of materials for managers to use. They wanted to make it easier for managers to send the right message.
Howard has taken a risk-based approach to training and compliance at Hewlett-Packard. There is a conflict between centralized training and distributed training. They allow district managers to assign training to employees. There is still a set of required training based on job function. Formal training is just one aspect of compliance training. It’s all of the other messages sent to employees.
The panelists emphasized the need to have face for your compliance program. It’s important to get local champions. You don’t need them to be compliance experts. You need them to be able to spot the issue and be willing to ask the question to the expert, compliance person or legal counsel.
Howard pointed out the need to avoid “compliance training.” You need to have compliance built into business operation training. Training merely to “check the box” will not be effective.
It’s important to remember that not doing something also sends a message. If people do something wrong and do not suffer consequences that sends a message.
A practice note from the panel was to send out messages about the importance of training before the training session. Send out messages about recent failures of anti-money laundering in the news to people before they attend their anti-money laundering training. Training is expensive so you need to maximize the value to the company and the participants. Let them know the importance. Give them tools to help them better understand the issues in the context of your business.
One interesting challenge with training the board of directors is that for board members who sit on multiple boards they get training fatigue.