Patrick Wellens (email@example.com) is currently working as a Global Compliance Business Partner for a division of a multinational pharma company, based in Zurich.
The United States Federal Sentencing Guidelines say, “Organizations shall take reasonable steps to communicate periodically and in a practical manner its standards and procedures and other aspects of the compliance program by conducting effective training and disseminating information appropriate to employees respective roles and responsibilities.” Despite compliance departments spending a substantial part of their budget on compliance training, employees are not always feeling engaged to complete compliance training and sometimes even question the usefulness of such trainings. This article highlights some of the success factors for compliance trainings.
Tailor training to the target group
Although employees understand the importance of compliance, often they are not very excited that they have to complete a large number of web-based trainings. These training activities take time away from more critical business activities, such as acquiring new clients, launching new products, and strategic projects. Therefore, it is of critical importance that face-to-face or web-based trainings are relevant for the person taking the training.
The aim of a compliance training is to inform employees of the legislation and company guidelines regarding a given topic and to provide practical guidance on how to respond in specific situations. Clearly antitrust risk is higher for employees working in sales, human resources, or research than someone working in accounting. Likewise, the risk of manipulation of revenue recognition and inventory “stuffing” is higher with accountants and sales employees than human resources. A generic training on data privacy might make sense for most employees; however, specific target groups that work with sensitive personal data should receive a more advanced training. Likewise, the board of directors or regional management need another sort of compliance training than the average factory worker. Therefore, it is critical that the allocation of web-based trainings or face-to-face trainings is done for the right audience. Although there might be cost and time constraints on the number and type of face-to-face compliance trainings that can be given, providing overly broad compliance training on topics that are not relevant for particular departments or employees does not help the reputation of compliance and contributes to it being perceived as “non-value added.
Some companies make the mistake of rolling out a generic, web-based training to too many employees without taking into account the professional experience of those employees. Clearly someone at the beginning of their professional career and a seasoned professional with 15 or more years’ experience should not be given the same generic training. It’s highly likely that seasoned professionals have already encountered similar antitrust or anti-corruption trainings in previous companies. To overcome this issue, it is good practice to evaluate the employee’s knowledge prior to the start of a training. If the employee’s score on the initial assessment exceeds a certain value, then that training should not be rolled out to them and the employee should move on to the more “advanced” level.