In a new Compliance Week article, Striving toward a better ethics and compliance training program, CREATe CEO Pamela Passman weighs-in on findings from NAVEX Global’s recently published Ethics & Compliance Training Benchmark Report. In the report, 929 respondents answered questions on the maturity of their ethics and compliance (E&C) training program and what actions are included in the program.
The maturity of these companies’ E&C programs are rated into the following categories:
- Reactive: Program addresses issues as they arise with no formal plan (10 percent of respondents)
- Basic: Program trains on basic topics only (32 percent of respondents)
- Maturing: Program has a basic plan for the year that covers a handful of topics with limited risk and role-based topic assignments. Effectiveness measures are limited to completion rates and qualitative feedback (48 percent of respondents).
- Advanced: Program has a sophisticated multiyear training plan covering a variety of topics assigned to specific audiences based on need and risk profile that includes live eLearning, short-form and long-form courses, and a variety of engaging formats. A disciplined approach to reporting and measuring training effectiveness that focuses on training outcomes (10 percent of respondents).
Passman suggests that a company should consider taking a risk-based approach. She says, “Defining a company’s risk profile and mapping specific training to the appropriate learners can help to better allocate resources and mitigate top risks.”
According to the report, companies with advanced programs are more likely to apply multi-year training plans. Key measures of a multi-year training plan include:
- Identify and prioritize risks and learning objectives;
- Identify the groups to be educated on each subject;
- Determine the time, frequency, and depth of communication;
- Determine which training methods to use (live, online, documents, or multimedia);
- Determine who is responsible for the delivery of that content;
- Document how to record employees’ receipt of training; and
- Determine how to measure the effectiveness of the training.
The objectives among the various maturity categories are noticeably different, with mature programs indicating their top objective as “creating a culture of ethics and respect.” Reactive and basic programs, in contrast, tend to have their top objective listed as “complying with laws and regulations.” Respondents to the survey listed their strategies for promoting a culture of ethics, which included training, coaching, and awareness efforts; intolerance of unethical behavior; and executive buy-in and leading by example.
Despite the emphasis on training programs, most respondents do not measure the return on their E&C training investment. Companies should measure the outcomes of their E&C training programs in order to track their effectiveness. Measurements should include performance evaluation metrics, behavior metrics, culture metrics and employee satisfaction metrics.