The other day I was talking with a compliance officer at a global pharmaceutical company, responsible for training employees from Morocco to Australia and all points in between. So, he asked, did I have any thoughts about what makes for effective compliance training?
I loved his question because the compliance community talks all the time about how to build systems of training: live events, web-based learning, quizzes, questionnaires, video clips, employee newsletters. If we wanted to list all the methods of training available to compliance officers, we could continue all day long.
He knew about all those methods and techniques, my friend said. But which ones actually work the best?
That’s something we talk about much less. Or more precisely, we don’t talk about all the tools at a company’s disposal to influence employee behavior, and how compliance officers need to assemble those tools in the right way to find a method that “works.”
For example, just earlier this week I mentioned a company I know trying to integrate text messages into its anti-bribery program. An employee would book a trip to a foreign market, and log that trip with the company before he departs. Then, as he’s waiting in the departure lounge at the airport, a text message appears on his phone: “Good luck with the trip! If you need a reminder on the company’s anti-bribery policy, do us a favor and click on this link to read it.”
That’s not training in the traditional sense—but it is a technique to nudge employees to do something you want. And so long as compliance officers can get employees to follow the compliance program, your next step should be to declare victory and shut up.
Huge volumes of literature exist on this subject of nudging behavior. Cass Sunstein, a former regulatory guru early in the Obama Administration, literally wrote the book on it—Nudge: Improving Decisions About Health, Wealth, and Happiness, published in 2009. (Yes, it’s well worth a compliance officer’s time to read.) The brothers Chip and Dan Heath have churned out one book after another about how people make decisions and how organizations make changes endure. Academic papers abound online.
Nudging is not training. Nudging is crafting the right procedure to steer employees to some desired behavior. What frustrates me is that nudging seems to work well in small doses: a reminder about anti-bribery policy just before your flight leaves, or requiring people to sign an ethics pledge before they take a training class rather than after it. The challenge emerges when we want to scale nudging up, from a class of 30 to a workforce of 30,000.
At scale, compliance training is more an exercise in risk management, to avoid the wrath of regulators or the boss. If you can prove that your company spends boatloads of money on training and puts employees through the courses diligently, regulators are more likely to focus their wrath on the offending employee rather than the organization as a whole.
That is not a bad thing, and in no way am I trying to say training is unimportant. But putting employees through the paces of compliance training is not the same as changing employee behavior—which is the ultimate goal. Many other devices, including nudges, can help training to achieve that. We just haven’t mastered the art of how to do that altogether.
What we need is a better understanding of how to piece together holistic efforts to change behavior—training courses, controls, procedures—for large groups of people. We have plenty of research on both halves of the solution, training and nudging. Now we need to figure out the best ways to fit them together, so the whole is greater than the sum of the parts.
For now, I’m sure, compliance officers continue experiments to find the right mixture at your own organizations. Let’s open up the conversation to develop some common practices for all organizations.
What works at your business? How do you decide on web-based training versus in-person meetings? What’s the criteria for teaching a whole class at once, rather than online courses employees take on their own schedule? How much time do you spend thinking of good “nudging tools”—and who helps you find them? Where are the HR and internal audit departments when you ponder all this?
We have lots of questions worth answering here. I applaud my compliance officer friend for starting the discussion, and he plans to do more research on the subject. I’ll keep you posted.