Training is the most visible and effective interaction compliance professionals often have with employees. So it’s crucial for Compliance to get training right. Yet, there is no real consensus about what constitutes effective training; training that demonstrably improves risk clarity in the organization.
In the absence of such certainty, compliance programs are often left to the mercy of vendors, consultants, and word of mouth, each heralding the “next best thing” in compliance training. Most recently, for example, the conversation has turned toward “gamification” as a way to make all training more effective, both for compliance and many other topics.
Compliance programs need a more scientific basis for training decisions. Executives must understand which training approaches and features are most successful in affecting employee behavior and reducing misconduct at work.
To better understand what makes training effective, CEB Compliance and Ethics surveyed more than 100 compliance executives and 3,000 employees. We examined different training approaches and their varying effect on employee behavior, and found that the answer is simple: to increase training effectiveness, focus on application. This means help employees apply compliance concepts to their jobs.
The Current Training isn’t Working
Employees are not satisfied with the compliance training they’ve been offered (see chart 1):
- Only 32% of employees agreed or strongly agreed that the compliance training they received over the past year was engaging (defined as training that “holds my attention throughout the course.”)
- 39% agreed or strongly agreed that the training was applicable ( defined as training that is “helpful and relevant to my work.”)
- Perhaps most disappointing, only 44% of employees agreed or strongly agreed that the compliance training they had received was informative (defined as training that “raises my awareness and/or understanding of compliance and ethics issues.”) This is surely the bare minimum expected of any training course.
Chart 1: Employee Feedback on Training Attributes Percentage of Employees Strongly Agreeing to Training Attribute
Note: Employees were asked their level of agreement with existence of each training attribute on a 7-point scale where 1 represents “strongly disagree” and 7 represents “strongly agree”. Employees classified as “agreeing” or “strongly agreeing” if they had scores of six or higher on the scale.
|Accessible: Convenient to access and participate in||Empowering: Confident to take appropriate actions as a result of training|
|Applicable: Helpful and relevant to work||Engaging: Holds attention throughout course|
|Informative: Raises awareness and/or understanding of compliance and ethics issues||Efficient: Course content is presented in the right amount of time|
The picture doesn’t improve when we look at an important measure of compliance program success: observations of misconduct.
CEB Risk Clarity data shows that levels of observed misconduct at work have remained relatively unchanged since 2009 at around 14%. This suggests that though compliance programs are doing more training, it has not been effective in changing employee behaviour and reducing risk.
These results are disheartening, and certainly don’t reflect the outcomes Compliance hopes for. With limited time and tight budgets, compliance teams should focus training on employee application to improve this state of affairs.
Focus Training on Employee Application
This year’s CEB Compliance & Ethics research found that the best training is application-focused. As above, this means that the best training programs help employees apply compliance concepts to their jobs. Application training has two key components:
- Relevant Skill Development: Application training provides employees the opportunity to practice the skills and decision-making processes most relevant to their real workflows and pressures.
- Motivation: Application training also motivates employees to apply training lessons in all contexts.
The benefits of this approach are substantial. In its employee survey, CEB found that an average of 28% of employees had observed misconduct in the past year. For employees who received strong application training, that number was 20% (see chart 2).
The story gets better as we move to reporting rates. Among employees who have observed misconduct, an average of about half reported what they saw. In contrast, 72% of employees who received strong application training reported observed misconduct.
Employees that receive application-focused training also demonstrate higher levels of engagement and discretionary effort. Overall, application-focused training–particularly when targeted to high-risk employee segments–reduces employee observations of misconduct, raises reporting rates, and creates more engaged employees willing to go the extra mile for the organization.
Chart 2: Distribution of Employees by Application Index Score Application Index Scores and Corresponding Outcomes, 2013
Four Ways to Create Application-Focused Training
Compliance executives can make small adjustments to their training program and stay within tight budgets. Consider four options:
Orient training around relevant tasks: Leading compliance programs create training modules centered on a task that simulates the scenarios employees face in their day-to-day work activities.
In this approach to learning, a full risk topic is divided into a series of shorter segments, each focused on a task employees must complete as part of their role (e.g., filing or approving expense reports). In contrast with the standard information-centric approach to training, task-based learning keeps employees’ attention, (leading to a higher retention of knowledge), and develops employees’ ethical decision-making skills by providing practice with real-world situations.
Make application-focused training scalable: Leading compliance programs leverage employees’ understanding of risk clarity to make potentially expensive customization more affordable and scalable.
Smith & Nephew ensures that employees only receive relevant training content by deploying a risk management checklist at the start of training modules. Based on their answers to the questions, training content is tailored to their need and risk level. In another example, Covidien ensures local relevancy for all global employees by using Ethics Circles— employee developed and facilitated live trainings—to address local knowledge gaps or cultural differences.
Work with employees to remove barriers to application: Employee work environments are more complex than even a sophisticated scenario or simulation can account for. Encourage employees to identify and overcome barriers to training application on the job.
Salerno (a pseudonym) holds a live follow-up session with high-risk employees to discuss the obstacles they encountered when trying to use compliance training in their workflows. Employees and the trainer brainstorm ways to avoid these obstacles, boosting training application in the organisation.
Provide implementation support: CEB data shows that employees who do not receive training reinforcement observe 27% more misconduct and report at rates 21% lower than those who do receive reinforcement. Providing employees with post-training implementation support is crucial for encouraging employee application of training concepts.
Johnson & Johnson uses a mobile app to ensure that employees can access abridged compliance guides targeted to their roles when they need it most.
CEB Compliance and Ethics Leadership Council offers members a variety of resources to support effective training, including: member case studies, a new vendor selection tool, a step-by-step guide to building a risk-based compliance training curriculum, and a training benchmarking report.