Compliance Week columnist Tom Fox recently sat down with Shawn Rogers, lead counsel, compliance training and communications at General Motors, to discuss the innovative steps GM has taken toward improving compliance training. Rogers spoke about the process, content, and results.
CW: You have a very unique job title. How did you end up at GM with this role?
SR: Prior to becoming an ethics & compliance practitioner, I managed corporate training programs at WordPerfect, Compaq, and Hewlett-Packard. I then got a law degree and went into compliance. In 2016, GM was beefing up its compliance program. Recognizing the importance of training and communications in an effective compliance program, GM was looking for someone with a background in both training and compliance. GM liked the idea of a compliance guy who had managed training programs.
CW: What did you tackle first?
SR: I tackled a few things at one time. I worked on the compliance training governance where we created a formal charter for the governance team that established the scope of authority and responsibilities. We established a meeting cadence and expanded the membership to include risk owners from across the company.
I conducted a training needs analysis to determine what the future training program should look like and what content should be included—the output of which became the GM compliance training framework. This framework sets forth our compliance training strategy that is both risk-based and tailored to GM's target audiences.
Finally, I reached outside of GM to find a couple of well-known compliance training providers that could become a long-term partner to help us elevate the professionalism and effectiveness of the courses. We pulled in stakeholders from across the company, and we were careful to include the team that handles our internal learning systems. We asked a lot of questions, tested some sample courses to make sure they would work on our learning platform, and checked references to find out about the experiences other companies had with these vendors.
“Every training professional I know struggles with proving training effectiveness. Proving or demonstrating training effectiveness is the holy grail of training programs.”
Shawn Rogers, Lead Counsel, Compliance Training & Communications, General Motors
CW: One of the key requirements from the Justice Department is that training be “tailored” to and effective for GM’s risks. How did you go about meeting those criteria?
SR: To have a tailored program, you must understand your company’s unique risk profile and your various training target audiences. For example, employees that work in sales, engineering, and procurement will have completely different risk profiles. You have to figure out a way to adapt the training program to address their risks while at the same time not asking them to take training on topics that are completely irrelevant to their specific jobs.
On the other hand, there are some topics that are applicable to every employee in the company simply because they wear a GM badge. The training architecture is designed to ensure that our compliance training program is both risk-based and tailored.
Every training professional I know struggles with proving training effectiveness. “Proving” or “demonstrating” training effectiveness is the “holy grail” of training programs. I don’t know if you can ever actually “prove” that your training has been effective. There is simply no way to prove that your training prevented a specific problem from occurring.
Let me give you an example. After 25 years of ticket-free driving, I got my first moving violation during my first month in Michigan. To mitigate the damage to my driving record and insurance rates, I took a defensive driving course. That course taught me the nuances of Michigan driving laws. (Michigan is the only state I know of where you sometimes have to turn right to go left.) It raised my awareness of distracted and fatigued driving. After taking the class, I realized that I was driving more defensively.
Now, can I say that the course prevented me from having an accident on my drive home from work today? Maybe it did. Maybe it didn’t. I do know it was an effective class, but I can’t prove that it prevented an accident. That’s the quandary that a training program has when trying to prove effectiveness. You just can’t prove a problem was prevented.
Here is why we believe that our approach is effective:
We build our training program based upon a well-thought-out strategy, overseen by the chief compliance officer
We customize the program to GM’s risk profile
We base our courses on the “influencing factors” to address GM’s unique culture and training needs
We use best-in-class partners who are professional instructional designers and who understand adult learning theory
We keep the training courses engaging and relevant
We enforce completion requirements with consequences for non-completion
We use end-of-course surveys to ask about the training relevance, we review the survey responses, and we implement suggestions
We ask our colleagues and peers for their opinions
We strive to continually evaluate and improve the materials and our approaches
I think even more importantly, we continually measure the overall compliance program by conducting compliance program assessments and ethical culture surveys. I believe that a solid training program contributes significantly to the effectiveness of the overall compliance program, which is consistently measured for effectiveness.
CW: How has the compliance training framework been received?
SR: The feedback has been very positive. The survey responses are running about 10/1 positive. My favorite comment so far came from a colleague on the GM legal staff. He stopped by my office after completing a couple of his courses and said, “Good job! The training is not near as annoying as it used to be!” I’m still laughing. I guess there’s still some room for improvement next year.