The beginning of fall marks many things in the lives of Americans— shorter days, kids going back to school, a chill in the evening air, and renewed worries about hurricanes, at least for those of us living along the Gulf Coast or Eastern seaboard, as their prevalence increases in September and October.  

It was while watching a broadcast about hurricanes a few years ago that I began thinking about my own company's approach to compliance communication and training. The focus of the program was on preparedness and, specifically, on whether those in high-risk areas had taken the time to really think through a plan to implement in the event of an approaching hurricane, as opposed to just reacting to an impending storm on short notice. The lesson here: A proactive approach rather than a reactive one is critically important when creating and delivering effective compliance communication and training.

From discussions I've had with compliance professionals over the years, I suspect many companies don't have as robust a compliance training and communication plan as they would like. Sure, they periodically send out notices about compliance-related issues and may even push periodic training to their employees, but these activities are not really a holistic solution for a broader compliance communication plan.

As I embarked on my own journey to develop an effective compliance communication and training plan at CA Technologies, I learned a number of things about our company, our employees, and our business.

Below, I provide an overview of what I learned and a few tips for building an effective compliance communication and training plan.

1. Have a plan. Determine exactly what it is that you are trying to accomplish with your compliance training and communication. Develop one or several goals. At first glance, the answer might appear to be self-evident. Aren't we all trying to ensure that our employees comply with the law and with our policies?  Of course, the answer is yes, but I don't think that tells the entire story. The full answer will likely depend upon a number of elements, including the makeup of your employee base, the type of industry you are in, the financial well-being of your company, and the level of executive support you have for your compliance efforts.

2. Understand your business. Compliance training and communication are not “one-size-fits-all” propositions. To truly be effective, they must be tailored to the business they support. Understanding your business includes an honest assessment of the risks faced by the business, as well as thoughtful consideration of how to best deliver lessons and messages to employees and leaders working within the business (which likely will differ across business lines within the same company).

3. Engage with the business. The best way to learn about the business you support is to regularly engage with it. Too often, compliance professionals are perceived (rightly or wrongly) as operating with an “ivory tower” mentality that is detached from the realities of the day-to-day business. Regularly engaging with employees at all levels of the business pays huge dividends in a number of areas, including gaining a better understanding of the training needs of the company, as well as building credibility for the compliance function within the organization.

4. Look in the mirror. How credible and respected is your compliance organization? And why do you believe you have the right or wrong level of credibility and respect? Performing an honest assessment of your compliance function is not easy, but it is essential. Building relationships with the business takes time, and there is a natural inclination for those in business units to view those working in compliance functions suspiciously. Are you doing things that increase or decrease the divide from the business? Do you have the right level of trust and transparency? While these types of questions may seem unrelated to the issues of compliance training and communication, the answers will often indicate how effective your training and communication with employees will be.

The lesson here: A proactive approach rather than a reactive one is critically important when creating and delivering effective compliance communication and training.

5. Make it interesting, relevant, and useful. We should all strive to ensure that the communication and training we push to employees is interesting, relevant, and useful. These goals may seem obvious, but actually reaching them is easier said than done. We need to address complaints that compliance training and communication is boring; and that it's unrelated to an employee's job. Or that the training is designed to simply tell employees what to be afraid of without offering any practical advice on how it applies to their jobs. If communication and training is tailored so it becomes relevant to employees, is delivered in an engaging manner, and provides information that employees can use in their day-to-day work, the level of interest and comprehension will certainly increase.

6. Think globally. Many U.S. companies operating on a global basis have a bad habit of being U.S.–centric in the things they do, including compliance-related activities. Whenever possible, your compliance communication and training should mirror the scope of your business, particularly if you are in a global business. This includes finding ways to train and communicate in the local language, with an understanding of the local culture and references to the local law. Employing a global framework will help to overcome the perception that compliance is a United States issue and reinforce the importance of compliance in the employee's own country or region.

7. Get others involved. Missionaries are effective in spreading the gospel because they rely on evangelists. This is also true for effectively communicating compliance messages within a company. Your job includes building a team of evangelists. Employees expect to hear messages about compliance and the law from company lawyers and compliance professionals. However, when they begin hearing these same messages from the people who lead the business, they are more likely to sit up and take notice. Tone at the top is a vital contributor to building an effective compliance program, but don't underestimate the importance the middle layer plays in helping evangelize your message.

8. Say what you mean and mean what you say. Clarity of message in compliance communications is critical, and compliance functions must back up their words with actions. Too often, employees disregard “mandatory” compliance activities only to find that there are no consequences for failing to complete them. While the goal of compliance is not finding ways to punish employees, we don't have the luxury of living in a world without consequences. You need to be clear about deadlines and ramifications for not meeting training deadlines. Specifically state your case for compliance cause and effect.

Effective communication and training are important foundational elements of any successful compliance program.  As you work towards improving your program, I hope these tips will prove as useful to you as they have to me. 

Joel Katz is senior vice president and chief ethics and compliance officer at CA Technologies, one of the world's largest independent IT management software companies.