“Do as I say, not as I do” is not an explicit policy one would find in any corporate code of conduct, and yet it’s an adage by which too many senior leaders and middle managers still operate by today.

The trouble with that leadership style is that corporate culture doesn’t work that way. The way that the business is run is the way that business is done, which means that no matter how many policies and procedures a company implements, all of it is for nothing if the corporate culture itself is toxic at its core.

Culture is the “holy grail” of ethics and compliance programs, but it’s also the one area that ethics and compliance officers struggle with the most, said Carrie Penman, chief compliance officer and senior vice president of advisory services at NAVEX Global during the 2016 Ethics and Compliance Virtual Conference.

Recent findings from NAVEX Global’s 2016 Ethics & Compliance Training Benchmark Report further demonstrate the extent to which ethics and compliance officers are struggling to ensure E&C programs positively influence culture. Over the last three consecutive years, when asked what training objectives were most important to them today, the majority of ethics and compliance professionals surveyed selected “creating a culture of ethics and respect” as their top priority.

Following closely behind culture, other top training objectives selected by the majority of respondents in NAVEX’s training benchmark report was “complying with laws and regulations” and “improving employee understanding of compliance priorities and obligations.”

Even though culture is the number-one priority for the majority of ethics and compliance professionals, many still don’t appear to be giving the subject the time and attention that it deserves. “When curriculum maps on training are put together, they almost always focus on hard and fast laws and regulations,” said Randy Stephens, vice president of advisory services at NAVEX Global “You don’t see that same level of investment, often times, in what is perceived as a softer skillset.”

NAVEX still gets approached by many companies that say, “‘I want to talk about organizational culture and respect, and I want to do it in ten minutes or less,’” Penman said. This check-the-box mentality can not only send mixed messages to employees about the importance that the company places on culture, but also has the potential to create cynicism among employees, she said.

“When curriculum maps on training are put together, they almost always focus on hard and fast laws and regulations. You don’t see that same level of investment, often times, in what is perceived as a softer skill-set.”
Randy Stephens, Vice President, Advisory Services, NAVEX Global

Several obstacles, however, continue to hamper the success of ethics and compliance training, including limited hours available for training and keeping content up-to-date with changes in regulations, each cited by 36 percent of ethics and compliance professionals in the training benchmark survey. Measuring training program effectiveness (30 percent) and not enough budget to create desired program (26 percent) also pose significant challenges.

Creative solutions

Budget and time constraints are driving leading companies to get creative with their ethics and compliance training techniques. In fact, maturing and advanced training programs realize far more benefits than programs that train only on basic topics, or are reactive in nature, according to the training benchmark report.

Common characteristics of maturing training programs include having in place a basic plan for the year that covers a variety of topics; limited risk and role-based topic assignments; and effectiveness measures that are limited to completion rates and qualitative feedback.

Advanced training programs, on the other hand, tend to have sophisticated multi-year training plan that covers a variety of topics assigned to specific audiences based on need and risk profile that includes live and e-learning; short-form and long-form courses and a variety of engaging formats; a disciplined approach to reporting; and measuring training effectiveness that focuses on training outcomes.

Examples of benefits realized by maturing and advanced training programs include more effective execution of training programs, as well as clearer identification of gaps and an ability to cover more risk topics. Demonstrating the connection between training program maturity and desired outcomes may help ethics and compliance officers to advocate for investment in initiatives designed to drive program maturity, the NAVEX Global report stated.


Below is an excerpt from NAVEX Global’s white paper, “Six Lessons That Redefine Focused Compliance Training,” outlining four steps to a more effective training program.
Step 1: Assess the Current State of your Training Program
It’s not uncommon for an organization’s leaders to have a fuzzy picture about the current state of training in their workplace. Divided ownership and segmented budgets often help drive this phenomenon. But getting a clear picture of what you are doing, and what is working, is critical if you want to make your program better.
Step 2: Explore New Trends and Approaches
There is a flurry of activity in the training world right now that has resulted in a variety of trending training approaches—everything from gamification to mobile enabled courses. Some of these tools and strategies can enhance your training program. But just because something is hot now does not guarantee that it is effective or a good investment. You still need to be critical about the trends you incorporate and whether they will work in your culture and in the context of your program.
Step 3: Focus on the Topics that Matter Most
You could train on everything, every topic and every risk area... but that’s not effective or practical. No organization has the bandwidth to consume that much training. Rather, the key is to focus on the topics that matter most and make sure that what you are delivering and how it is being delivered is as good as it can be. Maintaining a strong focus can help you really add value and create impact for your organization.
Step 4: Chart Your Course – Curriculum Mapping 101
Once you know what you want to cover, you need to figure out how and when you will do it. Commonly called curriculum mapping, this process will help you establish the cadence and methodology for deploying continuous compliance learning. A well-designed map will help ensure proper coverage of your organization’s key risk areas, help avoid learner fatigue, and give you a big picture assessment of methodology and deployment strategies.
Source: NAVEX Global.

When it comes to measuring training program effectiveness, carefully crafted surveys and employee focus groups are cost-effective solutions. According to a NAVEX Global white paper, some questions to ask employees include:

Was the training relevant to your job?

Did you find the training engaging and enjoyable?

Were the lessons clear and understandable?

Has the training helped you make better decisions?

Has the training improved your opinion about our commitment to ethics and compliance?

Are you able to apply what you learned in training on the job?

Another way to improve the effectiveness of training and create a culture of ethics and respect is through peer-to-peer learning. Penman pointed to recent findings from the 2016 Edelman Trust Barometer, which showed that the views of peers and employees are perceived to be more credible than CEOs when forming an opinion of a company. Specifically, respondents said they’re more likely to trust an employee compared to a CEO as it concerns treatment of employees (48 percent versus 19 percent) and information on business practices and crises (30 percent versus 27 percent).

From a practical standpoint, “it gives us an opportunity to think about how to tap into peer-to-peer learning as part of the way we communicate within the organization,” Penman said. Some companies are already achieving this by supplementing their training with other learning tools, such as peer-to-peer online video clips.

Having local ethics and compliance liaisons is also helpful in fostering peer-to-peer trust. “If they’re well respected, they can play a really strong role in communicating and being a conduit for both delivering and receiving concerns and resolving them promptly,” Stephens said. Employees often times are much more comfortable approaching a local compliance liaison than they are management, or going outside the company, he said.

In addition to peer-to-peer learning, a transparent culture also cultivates ethical behavior. Do you report on a periodic basis to your employees the types and numbers of reports that have come over the hotline? Do messages to employees match behaviors? Do you find ways to help employees identify and address behaviors that breed cynicism?

Ethics and compliance officers may also want to consider the following employee actions in their companies to help identify where pockets of employee cynicism and, therefore, cultural concerns exist:

Can employees speak up without censorship?

Do employees have the ability to help lead, advocate, and influence?

Are employees treated—and do they treat each other—with respect?

Does your training feel like a check-the-box exercise?

Fostering peer-to-peer relationships also help build culture. “Peer-to-peer retaliation often is one of the most insidious types of retaliation, personally, I’ve witnessed in an organization,” Penman said. “So build that trust peer-to-peer, and have those conversations, as well.”

The significant obstacles that ethics and compliance professionals must overcome to keep training relevant and effective—too little time, too little budget, an ever-evolving and more complex regulatory environment—aren’t likely to subside anytime soon. So the more creative you can be in making content as timely, innovative, and engaging as possible, the more successful you can ultimately be in creating a culture of ethics and respect.