Six Lessons that Redefine Focused Compliance Training: Lesson Six

Read Lessons 1, 2, 3, 4 & 5

Lesson Six: Monitoring Corporate Culture

For years organizations have used training to successfully build legal defenses and better position their organizations against litigation and enforcement actions. Increasingly though, training is intended to serve a dual purpose which includes driving positive cultural and behavioral changes in addition to establishing legal defenses.

It’s no wonder that this dual focus has become more important to organizations.

Training is the single largest compliance budget category, and is one of the most visible program investments. (See CEB: Increasing the Impact of Your Training Investment). In a 2013 Corporate Executive Board Survey on compliance training effectiveness, respondents cited “improving the design, delivery, and impact of compliance and ethics training” as their highest priority (76% of respondents).

Accomplishing both facets of this dual focus require employers to be more vigilant with the training courses they select, how they are deployed and post-training reinforcement.  So, how do you know if your training is driving behavioral and cultural change? And, what can you do to make your training program more effective?

Culture, very simply put, is the way that things get done in your organization. Culture is impervious to policies and procedures—it does not matter how strong these words are on paper if senior leaders don’t set a consistent tone from the top, and middle managers don’t reflect that tone day-in and day-out. If values and policies are not perceived as important to leadership, and enforced accordingly, you will have limited ability to shape the culture and it will take on a life of its own.

Many organizations have a spoken culture that differs widely from their “real” culture. The disparity is often the result of a disconnect between the formal, verbal communications about values by senior leaders and the realities seen by employees on a day-to-day basis. If middle managers are not completely committed to living and enforcing the values and policies it erodes the credibility of your efforts to establish a culture of ethics and compliance. Corporate culture is indeed the makeup of your organization as a whole, but your managers have the responsibility of ensuring that each and every employee’s conduct aligns with the tone from the top and the words printed in your core values and policies.

If you want to measure effectiveness of training (and see if it really is changing employee perceptions and behaviors) you need to be open to discovering your organization’s “real” culture and establishing a baseline that you can measure your progress against.

Culture surveys are great start; find out what your employees think about critical compliance issues and training effectiveness. If you can, conduct employee focus groups and live feedback sessions; these sessions are likely to result in more honest responses, especially when conducted by someone outside your organization.

You will also need to determine the metrics you will use to measure success of your training efforts. The criteria you use will of course depend on the types of data your organization collects. Organizations that have embraced technology will have many more options as they consider their success metrics.

Some of the metrics you may consider using to assess effectiveness include:

  • Acceptance of training (training completion numbers)
  • Number and frequency of training repetition events
  • Analysis of hotline and case management data
    • Change in observed misconduct rates
    • Change in reporting rates
    • Change in substantiated claim rates
    • Changes in attitudes and culture metrics (via culture surveys and/or employee focus groups)
    • Post-training surveys/quizzes designed to check knowledge and assess effectiveness

Once you have selected your metrics, begin to monitor on a regular basis. Watch for changes and trends over time. Set goals and develop action plans against your results so that over time you are able to adapt and modify training events, methodology and content to develop a stronger and more effective program.

Make Training Mandatory and Track Completion
You cannot expect to drive behavior and culture change if employees aren’t expected to participate in training or if your culture does not see it as a critical part of business success. Ensure that senior leaders support your training initiatives. Communicate that support to every employee in your organization.

Middle managers must also see training as an important part of protecting the business and driving performance. If they don’t, your culture will not gain measurable lift from a great training investment. Make sure middle managers understand the value of training—help them understand that companies that build cultures of integrity and compliance outperform those that do not. Need proof? Check out this resource:

CEB’s Turning Ethics into Outcomes (2011)

Some additional tips to consider:

  • Make training mandatory–training programs that offer optional courses will not see the desired participation or behavioral change.
  • Ensure that everyone (at all levels of the organization) actually participates and completes the training.
  • Provide managers with specialized training that focuses on their unique responsibilities.
  • Get feedback from managers and business leaders about whether they think the training is effective.

Make the Message Continuous
To be effective, training cannot be a one-time event. Knowledge retention declines over time, and memories of annual compliance training fade rather quickly. Both adult learning theory and marketing research confirm the effectiveness of repetition—the more we are exposed to a message the higher the rate of adoption. Here are a few examples of repetition you may be familiar with:

Some simple ways to keep the message continuous include:

  • Planning post-training refresher events and follow-up sessions.
  • Utilizing burst learning to reinforce key messages in a format that different from other training experiences.
  • Providing managers with written and video-based video resources they can utilize in regular meetings
  • Utilizing social media tools to communicate with and reach employees (and other stakeholders) with ethics and compliance messages

More and more organizations are leveraging Burst learning to address the need to keep the message fresh.

Burst Learning is designed to address single topic areas, using engaging video scenarios and interactive exercises, all in 5-8 minutes of time. These mobile-ready learning modules can be accessed anywhere, anytime and can be deployed through content delivery networks or your organization’s LMS.

Listen To Your Employees
If you want to know how effective your training is at driving cultural change, ask your employees. Find out whether the training actually helped them make better decisions, whether the information was relevant to their job, or if they have used what they learned.  If it’s not particularly helpful, it will not change behavior or attitudes and has no power to change culture.

Carefully crafted surveys and employee focus groups can be incredibly helpful. Some items you may want to ask your employees include:

  • Was the training relevant to your job?
  • Did you find the training engaging and enjoyable?
  • Were the lessons clear and understandable?
  • Has the training helped you make better decisions?
  • Has the training improved your opinion about our commitment to ethics and compliance?
  • Would you make a report if you witnessed misconduct? What types of misconduct?
  • Do you fear retaliation if you make a report?
  • Are you able to apply what you learned in training on the job?

Get Employees Involved in Teaching Others
One of the most powerful ways to improve training effectiveness is to get employees involved in teaching others.  When employees are encouraged to apply the lessons they have learned by teaching others they focus and apply learning in ways that improve retention.

In the CEB survey referenced earlier, employees who received compliance and ethics training that had a strong application value, saw the lowest observed rate of misconduct, had the highest reporting rate, and had the greatest retention of key lessons—by astonishingly high margins.

If it works in your culture, empower employees and managers to take the lessons learned in training and apply them in the workplace. Compliance advocates or champions can help teach other employees and field questions. Employees can help develop policies, and they can help develop training materials that will be relevant, powerful, and authentic to your culture.

Chat with a solutions expert to learn how you can take your compliance program to the next level of maturity.

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