When he worked as a lawyer at Tesco, compliance training was all about “ticking the box and getting it done,” David Ward told a Compliance Week Europe session on e-learning earlier this month. But his attitude changed when he became the retailer’s ethics and compliance director.

“From a compliance perspective, I really need people to ‘get it,’ so they don’t screw up, or that if they do, they know and can tell me about it,” he said. “That’s a critical difference.”

Ward was at the conference to share the story of how Tesco had developed a new approach to online compliance training—one that moved away from the rote, formal structure of so many programs to a more user-friendly approach that is inviting rather than intimidating.

Feedback on its old online training approach was terrible, he said. Modules were too long and contained far too much information. Trainees needed a computer equipped with a sound card, and headphones if they were sitting somewhere noisy.

There was a lot of “read this and click to move on,” says Ward. Lawyers wrote the course content and the questions, which trainees felt were designed to trip them up. “When we created the old e-learning modules, we were new to this stuff and it was an achievement to have anything, but we could see it wasn’t fit for purpose,” said Ward. “The style we were using was very old fashioned—people shaking hands, people looking scared—it just wasn’t authentic, and it was clunky. We wanted to do something that broke things down into chunks and was engaging throughout.”

Taking a Leap

Ward brought in an e-learning agency, Sponge U.K., to create new online modules that would train management staff on elements of the Tesco code of conduct.

“We wanted to be able to say, ‘Have you taken the leap?’ rather than, ‘Have you done your compliance training?’”
David Ward, Ethics & Compliance Director, Tesco

Deciding what to call the new modules was an important step. “If you talk about legal training or compliance training, that’s a massive turnoff,” said Ward. “So we came up with ‘the Learning Leap.’ We created an identity, a bit of a brand around the training program. We wanted to be able to say, ‘Have you taken the leap?’ rather than, ‘Have you done your compliance training?’”

Trainees complete the modules via a special online microsite, with fun, colorful animations. They start as Leapers, waiting in a jet plane. When they begin a module, they are Learners, floating toward earth in a parachute. When they complete, they are Landers, happily on the ground.

The microsite reports the number of employees at each stage of the process, with a breakdown showing the percentage at each stage across 180 different management teams.

This information is publicly accessible. “The idea it to build a level of competitiveness into the process,” said Ward, with each team trying not to fall too far behind the others.

Sponge U.K. developed an e-mail marketing campaign to encourage Tesco staff to begin and complete the training. If they don’t engage, the tone of the messages gradually changes from friendly and informal to stern and official. “We weren’t just saying do it because you have to—we wanted to give them positive reasons,” said Ward. The contractual obligation to complete training is only mentioned in the e-mails sent to staff who’ve ignored several reminders.

The results were impressive. Tesco had 4,000 staff who needed to complete an e-learning module on its gift-giving policy; 96 percent of them finished it. In a feedback survey, 70 percent said the training had improved their knowledge, 74 percent said the modules were the right length, and 92 percent liked the content. That’s a far cry from the stodgy, get-it-done training employees were used to.

Sticking the Landing


Below are excerpts from slides presented at the CW Europe conference by Tesco, detailing components of Tesco’s compliance training campaign:
Source: CW Europe.

To test whether the learning had “stuck” or not, Tesco sent everyone who’d completed the module a one-question e-mail on the course content. This happened six to nine months after they’d finished the course. 86 percent of them got the answer right.

The experimentation continues. In October Tesco rolled out a new e-learning module. Instead of punishing the 200 people who did not complete the last one, Ward sent them each a coffee mug, as a thank you for completing the course this year, even though they’ve not started it yet.

“This idea may completely fail, we will find out,” said Ward. “But we are looking for behavioral nudges that will get people to do the right thing.”

The vast amounts of engagement data that Sponge U.K. gathers and analyses helps Ward to try out ideas like this and to fine tune other aspects of the program. For example, he can identify people who complete the modules quickly and score highly, so he is looking at how they might become ‘ambassadors,’ spreading the good word about compliance training.

In the meantime, the new approach has worked so well in the United Kingdom that Tesco is rolling it out internationally.

Ten tips on developing an effective e-learning program for compliance

– Pick the right e-learning agency, as you will have to work with them closely

– Be open minded about how you might do things—compliance training doesn’t have to be boring

– Use as many relevant, real examples as possible in your scenarios, including anecdotes and experiences

– Make it sustainable: Think of it as a longer-term campaign, rather than a one-off

– Get your data in good shape. It makes it easier to run a good campaign, and helps you to gather valuable insights

– Avoid legalese. You are not teaching law, so use human and natural language

– If the training is global, challenge local teams to “localize” the content by adding their own context and examples. Don’t let them just translate it

– Think about where and when you will collect data for your “before and after” comparison, so you can judge what worked and what you could change next time

– Keep your stakeholders on board. Tesco directors received a lot of pre-briefing, nicely designed communications, and face-to-face information so they knew what to expect. (And remember to keep human resources involved. “I thought we could leave them out; quite rightly, they took offence at that,” said Ward.)