The Ethisphere 2021 World’s Most Ethical (WME) companies awards and reports were released last week. Over this week I have been examining these reports and information about the WME companies. There were three reports issued in conjunction with the 2021 World’s Most Ethical Companies; leading practices on managing a global workforce effectively, leading practices on managing third-parties risks, and leading practices in effective training and communications in a compliance program. (All available here.) In today’s edition, I review leading practices on communications and training (the Report).
The Report begins that as compliance programs have become more robust “it becomes increasingly necessary for ethics and compliance teams to map out a curriculum for training that allows for flexibility in knowledge delivery and also takes into consideration competing training needs from other functions.” However, not all employees need the same information as there are different risks for different levels and different types of employees. Obviously, clerks need a different level of compliance training than gatekeepers or employees engaged in sale with high-risk customers.
Erica Salmon Byrne, Executive Vice President and Chair of Business Ethics Leadership Alliance (BELA), Ethisphere, emphasized a company must manage its training. She went on to state “we did that because what our culture work has shown us is the manager is the fulcrum around which everything else works. If your managers are good ethical leaders, keeping an open door and employees are more comfortable going to them with questions. Indeed, employees are two times more likely to speak up. There’s data showing that the manager is central to the functioning of the culture inside an organization.” For these managers, training is critical.
The Report also spoke to the need for an oversight function in training as not “all employees need the same information at the same time, and different employee populations or topics require different modalities. In addition, launching online training at the same time as IT’s annual phishing testing is a recipe for disaster, so understanding what other parts of the organization are planning and when is critical. A good training plan will consider all of these variables. Every single one of the World’s Most Ethical Companies has a formally documented ethics and compliance training curriculum or plan. Some aspects of these plans are nearly-universal, such as specifying training delivered during onboarding or orientation.”
All of this leads to what the Report called “Targeting Audiences and Triggering Training”. In other words, who needs your training? It is beyond the manager which Byrne noted but the key is to have a plan for who needs training. It can range from “simple breakdowns between employees who need only basic ethics, compliance, and anti-bribery training, and a small cohort who need much more information. However, companies are increasingly trying to tailor their systems so employees only receive exactly the training they need, at the time they need it.”
Interestingly, the Report found “One trend that deserves special attention is the number of companies using triggers from other company systems to assign further training. Increasingly, companies are finding ways to deliver this type of “just-in-time” training by integrating with travel, reimbursement, or other key internal tools. Employees don’t have to remember complex or particular rules that may only apply to them a few times a year—they can get a reminder only when it matters. This saves their time and reduces the chance that employees will neglect their responsibilities.”
The Report also spoke to one of the biggest challenges for compliance professionals; how to determine compliance training effectiveness. Even the Department of Justice (DOJ) has focused on this issue. The DOJ’s 2020 Update to Evaluation of Corporate Compliance Programs has made it clear that the government expects companies to not only implement the program elements they outline, but to measure how effectively they are impacting the organization’s culture.
The Report listed multiple methods that companies use, some singular, some in concert with each other. Byrne explained, what “companies are doing right now is taking advantage of some of the technological capabilities which did not exist four or five years. They are layering, multiple data points and dashboarding.” It begins with the completion of the training, then layering with questions that come into managers or questions that come in regarding how to ask a question via the compliance email address. It also includes inputs from other functions such as timeliness of expense report completion which give a much broader picture of whether an employee understands and then implements what they learned in training. Indeed, the Report noted that “82 percent of companies now track how frequently training failures come up in root cause analysis of misconduct”.
The final area was monikered meeting employees where they are. The Report stated, “Even before the global pandemic required a greater move towards online communications, ethics and compliance teams were increasingly utilizing intranet portals and social media platforms to match the ways in which individuals have become accustomed to receiving information.” A plethora of tools and delivery strategies are employed, including “use email and intranet portals to communicate ethics and compliance messaging, and those channels remain strong. Other options, such as social media platforms, mobile-optimized materials, or podcasts, may see an uptick as socially distanced compliance departments try to reach their worldwide workforces. Several companies identified internal social networks as a key communication modality they have leveraged. Others are looking at converting their policies to a “Google-style” search format, to make it easier for employees to quickly find the guidance they need.”
Join us on Monday, where I continue my exploration of the 2021 WME information with Byrne when we will take a deep dive into all of the leading practices reports and the 2021 WME award winner.
Much of the information in this year’s WME awards and reports will be discussed in Ethisphere’s 2021 Global Ethics Summit, which will be held virtually April 13-15. Readers of this blog will receive a 15% discount to Ethisphere’s Global Ethics Summit For more information and registration details click here. Use the code tomfox15 for your discount.
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