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Ingrid Fredeen, JD and Mary Bennett, RPh

Building An Effective Compliance Training Curriculum

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Presenters Ingrid Fredeen JD, VP Ethical Leadership

Group

Mary Bennett RPh, VP Ethical Leadership

Group

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Overview

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Reality Check Reality Check

Too many needs

Too little time

Not enough resources

But training is essential in the compliance world

Communicate values

Meet legal obligations

Mitigate legal and reputational risks

Be thoughtful and thorough

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Curriculum Mapping

Education

Roles

Risks

Curriculum

Map

Education by risk & job role

Education by risk

Education by job role

Risks by job role

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Navex Global client survey results

6

Yes 40%

No 47%

Not sure 13%

Has your organization prepared a formal curriculum map for ethics and compliance

training?

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7

We don't map 38%

Not a total disaster

23%

Good 31%

Extremely well 8%

How well do you think your organization does at curriculum mapping?

Navex Global client survey results

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Effective Methods

Targeting, Depth, and Frequency

Identifying Risks

Curriculum Mapping Process

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Identifying risks and training topics

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Risks areas are determined by: Industry

Legal requirements

Changes in your business (acquisitions, right-sizing, etc.)

Internal drivers (culture, leadership, fear, etc.)

Internal trend data (i.e., litigation and agency proceeding data, hotline data)

Fact gathering & anecdotal evidence

Assessment results

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Assessing compliance risks

• Conduct a formal risk assessment with SMEs and business leaders

• Speak with internal subject matter experts

• Analyze case management data

• Conduct culture assessments, employee surveys and focus groups

• Review policy certification feedback

• Monitor for trends with eLearning

• Review pending laws/regulations

*Be prepared to take action on results.

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Not all risks are created equal. Assess each risk to help guide your level of response.

Consider the following for each identified risk:

• Likelihood/frequency

• Impact (both time and money)

• Who needs the training

• Goal (avoid, reduce, transfer, or retain the risk)

Consider using an attorney to assist with this assessment.

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Analyze the risks

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What compliance topics are most important to your organization?

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0% 20% 40% 60% 80%

Other

Union Awareness

Anti-trust

Insider Trading

Violence & Bullying

Reporting & Retaliation

Wage & Hour

Bribery & Corruption

Diversity

IT Security & Privacy

EEO/Discrimination

Harassment

Ethics & Code of Conduct

Source: ELT: Trends in Compliance Training (March 2012)

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Depth & Frequency

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The curriculum map

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Retaliation

Antitrust

Wage and Hour

Anti-bribery

Harassment

Conflicts of Interest

Ethics & Code

Discrimination

Determine the audience that needs training

on each risk area. Get granular if needed.

Don’t forget about new hires and

promotions.

For each audience,

determine depth and

frequency of training

For each group, determine the method and establish a calendar.

Keep in mind your budget and time

constraints.

Action 1 Action 2 Action 3 Risk Areas

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Risky Role: Employees who by nature of

their role engage in conduct that can create risk in a specified area

Spotters: Those who by nature of their role may see red flags or be able to spot an issue

(witness and report)

Aware: Those who should receive training to

enhance organizational culture and create general awareness

Targeting & Depth

Conduct in-depth training at regular intervals. Augment training with more

frequent, shorter training opportunities

Conduct in-depth training at regular intervals. Augment training with frequent,

shorter training opportunities with a focus on spotting and reporting

Conduct awareness-level training at regular intervals. Augment with reinforcement activities to help maintain culture and

promote reporting

Grouping Your Learners Determining the Depth

GR

OU

P 1

G

RO

UP

2

GR

OU

P 3

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Frequency Critical risk areas

• Full course training at least every 12-24 months

• Augmented with less formal methods of training on a regular basis

• Morgan Stanley did it right

For other risk areas:

• Should still be communicating with employees regularly

• Use more frequent but less extensive solutions to ensure employees understand expectations and resources

• Consider training a smaller audience using deeper dive approach

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0-3 hours 17%

4-6 hours 67%

11-15 hours 8%

+21 hours 8%

On average how many hours of formal E&C training do you deliver each year to each employee?

Navex client survey results

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Methods

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Assess Current State

• What methods are being used and how

successful are they

• What methods are most effective for your

audience

• Is training mandatory or optional; do you need to

change this

• How old is the current content; who will update it

or how will you get it refreshed

• Are you planning any technology enhancements

that could change delivery options

• Are current vendor relationships meeting your

needs

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Consider a wide array of methods

Formal

Live & eLearning full course

Manager-led live sessions

Informal

Group/team discussions

Collaborative learning and

social networking

Employee or peer-to-peer

learning

Sharing success stories

Awareness

Policy distribution

Burst learning

Paper/digital documents

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Evolve the way you communicate

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Internal social networking sites, some with video podcasts on specific topics

“Gamification” and encouraging departments to compete against each other

Manager meeting support materials (such as branching scenarios)

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Assessing effectiveness

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Update the map every 12-18 months

Assess success against prior

goals/objectives

Have any risk areas changed

Has business changed in any

fundamental ways over past 12-18

months

Assess new trends in training delivery

Linking evaluation methods to goals Level 1: Reaction Level 2: Learning Level 3: Behavior Level 4: Results Level 5: ROI

What it measures

• Were the participants pleased?

• Was the design and

presentation of the program engaging?

• What did they remember and learn?

• What skills, knowledge or attitudes have changed? By how much?

• Did participant behavior change?

• Are they more likely to do the right thing?

• Did it yield value for the business or organization?

• Did productivity, morale, and attitude improve?

• Were costly ethics and compliance violations averted?

• Compare program costs to company benefits, often in monetary terms and percentages.

Tools and timing

• Post-training feedback sheets

• Action plans

• Complete immediately or soon after training completion

• Uses surveys, quizzes, case studies, or similar

• Pre-test to establish baseline; post-test to measure change

• Post-test immediately/ up to one year after training

• Direct tools (surveys, progress on action plans) detect changes in learner’s perception of own behavior

• Indirect tools (questionnaire to someone close to learner) typically yield less biased results

• Collective changes detected with standard compliance measures (number and type of legal actions, helpline trends)

• Common tools: surveys, focus groups, and organizational data

• Must gather data pre- and post-training

• Measure over time and across organization

• Measurement examples: trust in management, respect for managers and employees, belief that the company will do the right thing

• Difficult to measure for ethics - can attempt to quantify money saved through avoided legal actions, fines and penalties, and reputational damage

Source: Creating and Measuring Effective Compliance Training, Mary Bennett, Compliance Today, Sept 2009

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Linking evaluation methods to goals

Source: Creating and Measuring Effective Compliance Training, Mary Bennett, Compliance Today, Sept 2009

Level 1: Reaction Level 2: Learning Level 3: Behavior Level 4: Results Level 5: ROI

Practical application

• Tools credible, inexpensive, easy to use

• Satisfaction does not always equal effectiveness

• Level 1 is most

common type of evaluation but cannot measure Guidelines’ effectiveness standards

• Helps improve content, design, venue, and facilitation

• Tools vary in cost and credibility

• Useful for identifying remaining knowledge gaps

• Level 2 evaluation is very useful with high risk audiences who must accurately know the content, as in meeting legal obligations

• Indirect tools difficult to implement

• Difficult to directly link measurements to training alone

• Behavior change is sweet spot for ethics and compliance training.

• Moderately expensive due to scope

• Results give insight to culture and possible impact of the ethics and compliance program

• Levels 2, 3, and 4

evaluation can be done with one well-designed survey –more useful when combined with focus group data

• Business leaders want this information, but most would see hard metrics for what they are – wild guesses

• Best question to ask when faced with ROI request: Will we stop our ethics and compliance program if we can’t show a financial return?

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Measure your training effectiveness

Review data sources for changes post-training

o Helpline data

o Legal actions

o Audit findings

o HR actions

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Evaluation common and best practices

Common practice

• Measures of reaction and learning (levels 1&2)

• Feedback sheets immediately after training

• Sometimes a survey or questionnaire at variable interval post- training

Best practice

• Pre-training survey/quiz

• Surveys to evaluate learning, behavior and results 1-3 months post-training

• Supplemental focus groups and analysis of organizational data

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Questions

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Thank you