Look Beyond Time and Money for Better E&C Training
More consecutive hours spent on computer-based training and more money invested in training programs do not necessarily add up to better outcomes for companies’ ethics and compliance regimes, according to the “2013 Ethics and Compliance Leadership Survey Report” from LRN, a corporate ethics and culture advisory firm.
For the report, LRN analyzed data gathered from a survey of 180 companies, many with a multinational presence, using what it calls a Performance Effectiveness Index (PEI). The PEI, a new feature in this latest iteration of the annual report, uses various metrics from companies surveyed to aggregate information about ethics and compliance programs and their successes and failures.
The report revealed that, although ethics and compliance departments and training programs must be resourced well to be effective, spending more money on E&C is not directly correlated with a more ethical and compliant workforce.
Wayne Brody, a senior leader at LRN who helped write the report, told CorpCounsel.com that in terms of program effectiveness, LRN found “it’s not a question of how much you spend but of how you spend it and why.”
Brody said that the survey revealed the programs with the highest impact were those most “embedded” in the life of the company.
“One of the things that really differentiates or is really true of highly effective programs—and not at all true of ineffective programs—is whether the company as a whole celebrates acts of ethical leadership and ethical distinction,” he said. The report indicates that of the companies that scored in the top quintile on the PEI, 79 percent said they focused on celebrating acts of ethical leadership by employees, for example by noting E&C successes in internal communications and team meetings.
Brody explained that companies can improve outcomes by integrating more ethics and compliance into performance reviews, and by taking a “blended learning” approach to delivering ethics and compliance messages—bringing lessons into everyday workplace life, rather than keeping them strictly in computer training modules.
In order to better accomplish this, the report suggests encouraging mid-level management, not just top executives, to set the tone for an ethical workplace and address compliance issues with employees.
“Most people never talk to the CEO of a large company,” Brody said. “They see him or her in passing, but that’s about it. The person that is the company to them, that reflects and communicates the company’s values and goals and so on, is their immediate supervisor.”
LRN’s report shows that companies may be catching on and acting on this concept, as 54 percent of respondents said they use team meetings to deliver E&C messages, an increase from 46 percent in 2011 and 38 percent in 2010.
This more localized approach, said Brody, can not only raise overall ethics and compliance standards, but can also help solve what he called the problem of “relevance” in E&C education, a disconnect that occurs when “everybody’s getting the same [training], but not everybody does the same job.”
Despite this emphasis on person-to-person ethics and compliance learning, computer-based training has still proven to be key. Brody emphasized its indispensability in setting global and company-wide standards when designed and administered well.
According to the report, computer-based training remains essential to most companies’ E&C regimes. More than 95 percent of respondents said they use it to some degree, and 75 percent rely on it for most or all of employee training.
Of the companies surveyed by LRN though, 60 percent cited “online education fatigue” as a top ethics and compliance challenge.
“We could see quickly that there was no correlation between program effectiveness—real effectiveness—and how many hours of computer-based training” the company provided, said Brody. “Whether it’s seven hours or three hours, it comes out the same.”
The PEI data indicated that the most effective training programs use multiple platforms—not just computer-based programs—and involve thematic campaigns deployed on at least a quarterly basis. Companies have been using social media more often, for instance, for ethics and compliance-related communications.
Creating innovative strategies for E&C training has proven important as well. Of the companies that scored in the top quintile for PEI, 86 percent identified innovation in design and delivery of ethics and compliance education as top goals. The net effect of this focus on innovation, the report said, is to “wake learners out of the slumber induced by the annual ‘hostage video’ computer-based training modules of the past.”