A compliance training program is only as strong as the corporate culture for which its stands upon, and yet several cultural-related concerns that threaten to undermine training program effectiveness continue to persist.

According to NAVEX Global’s 2015 Ethics and Compliance Training Benchmark Report, 37 percent of 677 ethics and compliance professionals polled said the top threat to training program effectiveness was “employee cynicism about culture change efforts.” Close behind was fear of retaliation, at 35 percent.

“When there is disconnect between the message and the reality, cynicism will fester and grow,” says Ingrid Fredeen, vice president of online learning content for NAVEX Global. “Distrust is much more present in an organization where actions are not aligned with the words.”

Even if a company has a perfectly polished Code of Conduct and says it prohibits retaliation, nothing triggers employee cynicism in the workplace more than when supervisors and middle manager don’t practice what they preach. Disconnect can be created when supervisors mishandle or downplay complaints or employee allegations, for example; that perception is supported by the findings of the survey: 26 percent of ethics and compliance professionals cited it as a concern.

The findings suggest that companies may not be doing as good of a job as they believe in getting middle managers to embody the message that their company doesn’t tolerate retaliation. That means they must keep reinforcing the message, says Jimmy Lin, vice president of product management and corporate development at The Network. “You’re not going to see overnight success,” he says.

Middle managers who don’t demonstrate ethics and compliance behaviors also add to employee cynicism and serve as a barrier to effective compliance training. “They should be visibly modeling values-based behavior,” says Marsha Ershaghi Hames, practice leader of education solutions at LRN. Middle management misbehavior was a concern cited by 34 percent of ethics and compliance professionals in the NAVEX survey.

Another factor that can undermine compliance training efforts is when “disciplinary measures are inconsistent or non-existent,” which 32 percent of ethics and compliance professionals cited as another top threat to training program effectiveness. Employee cynicism is “a symptom of a culture that either isn’t saying the right thing, or is saying the right thing but not supporting it,” Fredeen says.

“When there is disconnect between the message and the reality, cynicism will fester and grow. Distrust is much more present in an organization where actions are not aligned with the words.”
Ingrid Fredeen, VP of Online Learning Content, NAVEX Global

Senior leaders also play an integral role. “Tactics such as linking performance ratings, promotions, and pay to corporate values are a step in the right direction, but senior leaders must also provide appropriate executive level support for the program and hold middle managers accountable,” the NAVEX report said.

Senior leaders can also foster corporate culture by playing a “very visible role not only in talking the talk but walking the talk,” Ershaghi Hames says. That means finding opportunities to insert themselves into the conversation and “not just be a formal talking head—really make themselves approachable and integrated into day-to-day dialogue of the business.”

Ethics and compliance professionals who responded to the survey likewise stressed the importance of senior leadership engagement. Nineteen percent said that when senior leaders don’t communicate the importance of the company’s values, that also threatens to undermine compliance training effectiveness.

One hallmark of an effective training program is a “deliberate focus on the culture,” Ershaghi Hames says. “Employees have to feel like there is a consistent and authentic commitment to the program.”

Training Engagement

The good news, the report finds, is that most ethics and compliance professionals want to foster a healthy corporate culture—how to get there is what perplexes them. When asked to force-rank their top ethics and compliance training objectives, for example, a plurality of respondents (46 percent) cited “creating a culture of ethics and respect” as their top objective, followed by complying with laws and regulations (37 percent).

To achieve that objective, however, a check-the-box training program will not suffice. “They need to look for training that is engaging, informative, that is helpful and relevant—not just the least expensive, easiest, most simplistic solution on the market,” Fredeen says. Whether they’re building a compliance training program or buying one, she says, “they have to look for something that will really resonate with employees.”

One compliance training tactic that many companies are adopting today is awareness campaigns on social media platforms like Jive, Yammer, or Chatter to foster ongoing, dynamic discussions online, including internal discussions about integrity and compliance topics. “It’s not just about trying to shove training in someone’s face,” Lin says. It’s about creating conversations that naturally become part of the culture of the organization, he says.

Employees should also be involved in the training. “If employees don’t feel engaged enough in the conversation and in the topic, if the subject matter isn’t really relevant to them, that also can make it very challenging for the training to have any kind of impact on their behavior,” says Pat Harned, chief executive officer of the Ethics and Compliance Initiative, an information resource for ethics and compliance officers. “Having employees talk about situations that have happened to their peers, things that have actually happened in their company, makes it more real for them.”

Focus groups are another way to include employees in a positive way and avoid one-way conversations, Ershaghi Hames says. Questions to ask employees during those focus groups, could include, “Do you feel your manager is approachable? Do you feel you can communicate openly without fear of retaliation?” Answers to those questions will help paint a clearer picture of the corporate culture, she says.


Respondents to NAVEX Global’s 2015 Training Benchmark Report were asked, “Which Ethics and Compliance Training Objective Is Most Important for Your Organization?” Their responses are below.

Source: NAVEX Global.

Many companies are now also establishing “speaking up campaigns,” Ershaghi Hames says. In one particular case, for example, a company began to notice through its employee engagement survey that trust levels in leadership was dropping. 

To get to the bottom of why this was happening, LRN helped the company develop a campaign “to take the concept of speaking up and speaking out on the road,” Ershaghi Hames says, and directly to the employees of their manufacturing plants. What they found was that by talking openly about anti-retaliation and the importance of speaking up through focus groups and interviews where the issues existed, managers learned more than they ever would have through a campaign strategy developed at corporate, she says.

Through that experience, Ershaghi Hames says, the company was able to develop more targeted awareness around anti-retaliation: why it’s important to culture, how to collaborate and communicate more cohesively, and how it’s connected to their Code of Conduct. “By connecting a lot of this back to the business, it became more integrated in the day-to-day ‘how we live and what is our purpose,’ ” she says.

Culture is one of the biggest factors that drives employee behavior and employees’ perception of a company’s culture. So it’s important that both senior and middle management alike can maintain the company’s message that unethical or non-compliant behavior will not be tolerated. Being consistent, fair, and responsive to employee concerns will go a long way toward mitigating employee cynicism and foster a strong ethical culture.