Companies need to have a plan when they begin the process of creating or revising a compliance training and communication program. But what does that really mean and how do companies go about building or revising such a plan? The answer to these questions will likely be company specific, but let me offer a few thoughts and observations drawing largely from my own experience at CA Technologies.
When I took over responsibility for the company’s compliance training and communication in early 2009, the company was at a crossroads. Following an accounting-related government investigation, subsequent settlement, and the creation of a best-in-class compliance program, employees began to develop a bit of compliance “fatigue” after several years of their inboxes being inundated with compliance training messages and other compliance-related communications.
