Compliance Program Effectiveness: The Learner-Centric Approach



How will your ethics and compliance program be different a year from today? The New Year is right around the corner, and with it, a new set of training goals and launches. It's a time to be honest with ourselves, and I want to be honest with you. Here's the truth.  

Building an ethics and compliance program for a global, multi-lingual and multi-risk workforce is not easy. Changing behaviors around risk for thousands of unique people is a process built on repetition and reinforcement, not a quick-fix, checked box, or completion rate. 

Creating a culture where employees engage with ethics and compliance learning content is not easy. We're swimming upstream against years of preconceived (and sometimes earned) opinions that the content isn't actually a helpful or valuable way to spend ones time, while new risks present themselves constantly. 

Demonstrating program effectiveness and value with relevant data and analytics is not easy. We need to improve not just what we actually capture and measure so we have more data, but also the quality of the data itself. As part of that, we need to also improve the relevance of the experiences we deliver to each learner and why they're important to their jobs. We need to overcome a disconnect between our intention and execution. 

Just because something isn't easy doesn't mean it isn't possible. In fact, the hardest problems to solve often require the best ideas and most thoughtful solutions. If we don't acknowledge the challenges associated with accomplishing our goals, then we're destined to continue down the path we're on today instead of working even harder to overcome the barriers in our way. In doing so, we fail to adapt to a business landscape that won't stop and wait for us to catch up.  

Part 1: The Evolving Ethics and Compliance Marketplace – listen on iTunes

At the heart of any effective compliance program is a learning methodology and modern technology. A learning methodology, the logic and strategy behind how your program is built, addresses how we process, remember, and operationalize information today. Modern technology, the tools used to bring that program to life, is designed to deliver that content in alignment with a defined strategy, in an environment that can capture and measure the real data, analytics, and behavior we need to understand. In 2018, we've built EthicsAnywhere – a combination of learning methodology and modern technology, so you can take a learner-centric approach to E&C. By doing so, you'll be able to remove traditional barriers of consumption to create engaging and measurably effective experiences. 


Measuring Process vs. Measuring Outcomes

The intentions of ethics and compliance professionals are to help employees do the right thing and behave ethically so their culture can prosper and their organization can manage risk. Those good intentions are challenged by various pressures, like regulations that fundamentally change the way an organization does business, to ambitious individual goals and targets that can pressure a learner to 'win' at the expense of integrity and legality. When handled poorly, pressure creates coal. When handled well, pressure creates diamonds.

When executing on these intentions today, the E&C community often focuses on completing a series of tasks defined by regulatory bodies. When measuring the results of our efforts, the illusive concept of 'program effectiveness' is done through the lens of regulatory expectations. Often times, this neglects to consider if the actual learning experiences built for employees are effective in relation to what those intentions were. 

Part 2: The Shifting Compliance Mindset – listen on iTunes

When reflecting on her E&C experiences in a recent Bloomberg Law article, Hui Chen summarized this concept well: the pedigree of an athlete isn't measured by their hours in a gym but instead by their performance in the game. “In the area of corporate compliance, however, the focus has remained on process, not outcome.”

From my perspective, the focus has remained on regulators, not learners. Looking ahead to 2019, my resolution as the VP of Learning at SAI Global is to help organizations take a learner-centric approach to their ethics and compliance programs, and in doing so, create a more accurate and honest definition of program effectiveness. 

To do that, we'll have to overcome the four disconnects in ethics and compliance programs today: consumption, perception, evolution, and culture. Each of them are magnified by the growing consumerization of compliance; the undeniable fact that employee awareness around ethics and compliance issues has taken leaps forward, and so has the way technology influences how they comprehend and retain information. However, the driving forces behind the creation of E&C programs in organizations are still largely the same. 

Part 3: Ethics Anywhere – listen on iTunes

The Four Disconnects

1.  The disconnect in consumption exists because how your organization delivers learning content to employees today is significantly different from how your employees engage with content and information in their lives whenever they aren't doing work.

Research we conducted in 2017 showed us that 93% of organizations do not deliver learning content on smartphones and 81% do not use adaptive learning to personalize experiences for each employee. 

Research conducted by WordStream tells us that everyone in your organization, not just Millennials, spend more time browsing the internet and watching videos on their phones than their computers or laptops, and everywhere they visit is personalized specifically to them. Yet the majority of E&C programs today are delivering standardized, non-personalized or customized training to people that can only be engaged with at their desk on their computer.

2.  The disconnect in perception exists because of the difference between what regulators and employees think of your E&C program. While two hours of 'click and continue' online Code of Conduct training could deem your program satisfactory from a regulator's perspective, it could also disengage that employee and negatively shape their perception of ethics and compliance in your organization. 

Part 4: Trends in Culture, Ethics, and Compliance – listen on iTunes

3.  The disconnect in evolution exists because technology innovations and content trends move significantly faster than changes in laws and regulations, and the former is something your employee experience more directly than the latter. If you train employees on bribery and corruption in 2017, 2018, and 2019, the ways that you can deliver that information and they can consume it will change more significantly than any regulation or principle around the information itself over those 24 months. 

4.  The final disconnect is focused on culture, because what people learn does not correlate with how they behave. Just because you trained someone once to be competent about a risk topic doesn't mean they'll act differently or confidently when presented with that risk in real life. 

Part 5: Integrated Risk Management – listen on iTunes

If you're interested in adapting to the growing consumerization of compliance and taking a learner-centric approach that addresses some of these disconnects, there's no better time to start than the present. These changes won't happen overnight. As an ethics and compliance professional, you're well aware that meaningful change can take time. So let me help you take the first step and serve as a guide on the beginning of your journey to true, data-driven, authentic program effectiveness. 


In September 2018, I joined Tom Fox, the Compliance Evangelist, and Paul Johns, the CMO of SAI Global, for a conversation about these topics and the evolving E&C landscape on his podcast. You can listen to this five-episode series, called The Evolving Role of Risk, Compliance, and Ethics in Brand and Reputation, on iTunes, or with the YouTube clips embedded throughout this blog post. 



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