Most compliance departments are well aware of the valuable role that middle management can play in shaping a culture of ethics and compliance. How to work with them to achieve that objective, however, is where the challenge lies.

Traditionally, mid-level managers haven't played an integral role in spotting compliance and ethics risks, says Kirsten Liston, associate vice president of learning content strategy at SAI Global. Only in the last few years have companies started to come up with practical solutions on how to engage managers to turn them into advocates for the company's ethics and compliance program, she says.

The first step in educating managers on how to effectively deliver and promote the company's ethics and compliance message should start with taking their pulse and assessing what some companies call “the mood in the middle,” says Liston. “Put together focus groups to understand how managers think about compliance and ethics in the first place,” she advises.

The next step is to make sure managers understand how important compliance is to the company, says Liston, and let them know that it's a topic the board discusses regularly, and something senior management takes seriously. Not all managers may know, for example, that their compliance team regularly reports to the board on the status of the compliance program, she says. “Just sharing that kind of information can help managers see that the company takes compliance seriously and that they should, too.”

Companies should also ensure that managers understand what it means to be a role model for the company. At aluminum company Alcoa, for example, managers are given a reference guide entitled, “Be a Role Model! How to Be a Leader in Ethics,” which reinforces specific actions supervisors can take to create a culture of respect. In addition, Alcoa trains managers around the world about how to lead by example and take actions to foster an ethical workplace culture.

Simply telling managers what to do, however, is not enough. Managers aren't going to pay a lot of attention and devote resources to ethics and compliance training just because they're told, especially when it has to do with achieving business objectives, says Norman Marks, former vice president at SAP and an independent advocate for compliance, ethics, and risk management. “What you have to do is get managers to want to do the right thing,” he says.

The way to go about doing that is to make the compliance message meaningful to them, says Marks. Drive the point home that if they don't adhere to the company's ethics and compliance policies and procedures that it could result in things like loss of customers, reputational damage, or even fines and imprisonment.

“You really have to make sure you make it personal to each individual you're trying to educate. They have to understand that their actions have an effect on them personally.”

—Norman Marks,

Former VP,


“You really have to make sure you make it personal to each individual you're trying to educate,” says Marks. “They have to understand that their actions have an effect on them personally.”

Training Methods

For education and training to be effective, it must be tailored to the specific risks that each manager faces, based on their particular geographic location. “They have to make the case studies real,” says Marks. “It has to be something the person can relate to.”

Telecommunications giant AT&T, for example, has recently launched a pilot program that presents employees with simulated scenarios that raise compliance and ethics challenges. “It gives employees the ability to really see what the outcome could be based on the decisions they might make in a particular situation,” says Amy Rouse, director of AT&T Learning Services.

AT&T Learning Services also benefits from its partnership with the compliance team, which tracks any violations and concerns that are reported through a compliance dashboard. “We are very quickly able to see a trend that might be developing and develop a scenario to speak directly to that particular violation,” says Rouse. This then enables AT&T Learning Services to target that scenario to a particular call center, business unit, or geographic location, she says.

Management Training at AT&T

Below is an excerpt from AT&T regarding their “Leading With Distinction” program.

AT&T University is an executive-led program focused on leadership and management development. From the company's Dallas headquarters, where the main campus is located, courses are held onsite and in virtual classroom sessions, with satellite campuses across the United States.

AT&T University's “Leading With Distinction” program focuses on aligning managers at all levels with the company's strategy, and helps them become better leaders. Since opening in the spring of 2008, AT&T University has developed more than 100,000 managers a year.

In 2012, AT&T provided more than 21 million hours of employee training at a cost of roughly $280 million. Employees completed almost 27,000 courses daily through Learning Services.

Source: AT&T.



To simplify the management training process, Liston recommends that companies deploy training based off the tools they're already using. “If the company is already doing online training, for example, put together an online training program for managers,” she says.

In every situation, managers should know how to get ahead of potential problems, says Liston. “How do they respond to issues correctly and in a way that will prevent employees from having the same problem moving forward?” she says.

“Companies that have developed their own training are doing it effectively are those that already have a really strong compliance program and culture,” says Liston. “If you have a strong compliance culture, creating very simple tools for managers to deploy can make a huge difference.”

“They don't have to be fancy. They don't have to be expensive,” Liston adds. It just has to be something so that managers aren't developing programs in the dark, she says.

Leadership at Alcoa

Below is an excerpt from Alcoa's ethics and compliance program.

Leader's Guide

Alcoa's managers are expected to create a work environment that encourages a “speak-up” culture. Supervisors create a culture of respect and honesty in which employees feel free to dissent or raise business conduct and other issues without fear of reprisal.

We distribute to our leaders a reference guide entitled “Be a Role Model! How to be a Leader in Ethics.” The guide reinforces specific actions that can be taken by supervisors globally to create a culture of respect.

“Be a Role Model!” training supports the guide and is available in multiple languages on our internal Global Compliance training portal. This presentation examines the supervisory leader's responsibility to be a role model and lead by example, and it reinforces appropriate actions to foster an ethical workplace culture.

Ethics and Compliance Training

“Do What's Right!” Training. All newly hired Alcoa employees are required to participate in our “Do What's Right!” training, which serves as an introduction to our corporate Ethics and Compliance Program and our values. As part of the on-boarding process, employees also receive information about our Ethics and Compliance Line and a copy of our Guide to Business Conduct.

Online Training. Alcoa employees who meet certain criteria (i.e., corporate officers, business unit leaders, employees who negotiate with customers and suppliers, employees who can contractually commit the company, employees who have access to confidential information, etc.) are required to participate in online ethics and compliance training.

The selected courses serve to remind the individual of our business conduct standards and their applicability to the individual's work responsibilities. Those enrolled in the online training program complete approximately four courses per year.

In addition, we continue to use Ethics PinPoints and Moments to reinforce key messages with employees. Distributed via email, these short, multi-lingual reminders address our core values and standards. In 2012, we deployed five PinPoints and Moments on the following topics: intellectual property and use of third-party photos and materials; anti-retaliation; anti-bribery and dealing with public officials; social media; and e-mail security.

Shop Floor Training. Any Alcoa employee who does not participate in the online training program is required to complete annual shop floor training. The 2012 course was entitled “Standards of Business Conduct” and was designed to reinforce the key concepts of our Guide to Business Conduct.

The course emphasized the importance of knowing and complying with laws, regulations, and company policies; asking questions in uncertain situations; and raising concerns when known or suspected violations occur. The course also stressed that Alcoa does not tolerate retaliation against employees who raise concerns in good faith.

We translated the course into multiple languages for global deployment, primarily through instructor-led group sessions facilitated by human resources. However, shop-floor employees with access to a computer were given the option to complete the course online.

Source: Alcoa.



Another important element to training is to keep it fresh. “We really want to make the training meaningful and purposeful,” says Rouse. “So we seek ways to make the training engaging and enjoyable.”

One way AT&T is achieving this is through using gamification, which is the use of game mechanics in non-game contexts to engage employees in solving problems. In 2013, AT&T launched a “major initiative,” Rouse says, “where we converted a good portion of our compliance training to mobile devices to make it really convenient for our employees to take our compliance requirements.”

How long management training takes from start to finish all depends on the company. SAI Global, for example, offers an online training curriculum that is designed to be deployed over a period of six to 18 months, depending on how aggressive the company wants to roll it out, says Liston. Even without the use of an online training package, however, any company can put together its own training curriculum, “which would be way more than what they're already doing,” she says.

Management Involvement

Managers should have a way to provide feedback. “Look for ways that managers can have input into the compliance program,” says Liston. If you can get managers involved in terms of giving feedback, they're more likely to stay engaged in the program and delivering the company's ethics and compliance message, she says.

The compliance team should turn to them for feedback on such matters as where training is working well for their employees, where it is not, and what compliance and ethics topics should be covered that may not currently be covered. Allowing managers to have input into the style of the training itself may also be helpful, she says.

At AT&T, for example, AT&T learning services has a “really great partnership with compliance,” says Rouse. “We meet very regularly to prioritize the training, to talk about new training, and to discuss key strategies, like emerging technologies.”

“We keep them informed of all the new things that are coming—like gamification and mobilization and new trends and video and things. They, in turn, keep us informed of the regulatory requirements that are coming,” says Rouse.

That collaboration has played an important part in ensuring not only that all employees are in compliance with the company's policies and procedures, but that it's also an enjoyable process for employees as well, she says. “That open line of communication and the mutual desire to both design and deliver engaging effective training is where the partnership really gels,” says Rouse. “If we didn't have that relationship with the folks responsible for compliance, it would be a whole different ballgame.”