I spent most of last week on vacation in California, which required a cross-country flight to get there. Since compliance professionals fly all the time, you know what that means: flight safety videos.
And, naturally, thoughts on compliance training.
After all, one of the biggest challenges for compliance training is how to keep the material fresh, so employees pay attention to the lessons you want to impart. That’s true of the FCPA, social media policy, or collusion, just as much as it’s true of flight safety videos. We go through the lessons once or twice, absorb the main points, and then start to tune out during future lessons.
Compliance officers know this is true. How often do we need to be told that in the event of a water landing, we should pull on the red tube to inflate our safety vest? Or that the nearest exist might be behind us? Or that we should adjust our own oxygen mask before helping the child next to us?
My point is, every safety video begins with the same request: Please pay attention to the following message. And then we don’t, because we believe we know the material, although I’m willing to bet that during an actual emergency most of us will be as terrified as a deer on the highway.
I suspect a lot of compliance training runs that same risk. We train people on a regulation or procedure, rather than how the underlying risk might surface in daily routines that employees and third parties face. That encourages over-confidence and disregard of the material.
For example, I once had to take annual FCPA training for several years. Employees had to read about 10 pages of material, then take a 10-question quiz. If you answered seven or more questions correctly, you passed the training.
At that point I had been writing about corporate compliance and the FCPA for years, so I did the practical thing: skipped ahead to the quiz and took it. Training done. (For the record, I hit nine out of 10 questions in the first year, then nailed all 10 in the subsequent two years I took the training.)
Was I a good employee making efficient use of time, or an over-confident turd making compliance officers roll their eyes? I’m still not sure — but the same over-confident impulse led me to start writing this post before my flight safety video had even finished.
Fresh Takes on Old Training
Compliance officers also know the first rule of trying to make training material fresh: do goofy takes on it. On my airline last week (Delta), the safety video was a cartoon of the seat-back safety instructions. As the voice-over walked through rules about no smoking in the lav or not scrambling around to find a dropped iPhone, the cartoon characters reached through one panel to the next, like a comic book ignoring its panels. If you’ve flown Delta recently you know what I mean.
Other airlines have their own goofy takes. Animation seems always popular. I’ve seen videos that use human actors, but sing or rap their way through the safety lecture. Last time I flew Southwest there was no video, but the flight crew led safety demonstrations while cracking semi-funny jokes all the while.
You get the idea. When want to make rote training material interesting, the first instinct is to say, “Hey! Let’s do the rote material but poke fun at it! That will keep everyone watching and slyly convey that we also know this training is a bit boring. So clever, right???”
That approach works the first few times, and we can’t pick on the airlines too much because they have two constraints most companies don’t. First, airlines are trying to educate people on specific procedures: how to exit the aircraft, how to behave in an emergency, how to help the flight crew in a crisis. Second, airlines don’t have much say in who receives the training; customers are customers, and on any given flight you must assume most of them haven’t seen flight videos a million times over.
Those are important points for compliance officers to consider as you develop your own training materials, and try to devise ways to make that material stick.
That is, all compliance training aims to get employees to behave in certain ways — but not all training is about getting employees to follow specific procedures; and most firms do have far more control over who receives what training. So we could divide training into three broad categories:
- How to interact with a machine or a system (like filing an expense report);
- How to interact with other persons (like colleagues, competitors, or foreign government officials);
- How to interact in certain situations (an emergency landing, receiving a subpoena, or watching someone harass a coworker).
In any of those scenarios, how much do you want employees to follow a specific procedure, versus following certain standards of behavior?
Compliance officers need that answer clear in their minds. Then you can consider the best way to provide training that treats employees intelligently and also delivers the lessons effectively.
Just Talk It Out
This is also on my mind because of Ethisphere’s latest best practice analysis, released last week. As we previously noted, that report examined the role that managers play in encouraging a speak-up culture.
In its own way, that’s training. Managers are training employees to follow a certain standard of behavior: to speak up about misconduct when employees see it. So what’s the best way for managers to do that training? How often can managers deliver a pep talk or mandate a quiz about speaking up, before it sounds as cliched as a flight safety video?
Clearly, even just talking about ethics helps. As Ethipshere noted, at organizations where managers talked “frequently” about ethics with employees, those employees were more engaged in ethical conduct. (See chart at right.) Observing misconduct, reporting misconduct, believing senior management’s statements about conduct — across a range of criteria, the answers were better.
That’s not to say corny training videos have no role. They are excellent vehicles for new employees, new regulations, or standard procedures, where large numbers of people need primers on straightforward tasks. So as hokey as flight safety videos are, I don’t blame the airlines for using them.
Still, the best teachable moments don’t arrive on a predetermined schedule, neatly aligned to the talking points of a five-minute comedy script. They arise randomly, with extenuating circumstances. The best compliance training trains managers to take advantage of those moments, in informal conversations or ad hoc departmental training sessions. No animation or singing necessary.
Giving managers the tools, skills, and authority to integrate those teachable moments into daily routines — that should be a high priority for compliance functions. Then your daily routines might, finally, be less turbulent.