In many countries, manufacturers are required by law to place instructions and warning labels directly on their products. This is why our lawn mowers have a label like this one:
How did it start? With courts finding manufacturers liable for the injuries caused by their products. Courts realized that most people don’t read the instruction manual that comes with a product, and that those who do read them don’t always remember the warnings they contain six months or two years later. Courts essentially told the manufacturers that they could escape liability if they copied the warnings in the manual directly on the product, near the dangerous area.
There is a lesson here for those us responsible for ethics & compliance training. We all know that the standard model of classroom or online training is not the most effective. Plenty of employees who were trained on a specific policy end up violating that policy later on because they didn’t connect the dots between the training and the real situation they faced.
The solution offered by product liability law is to embed the training in the business activity itself. An online anti-corruption training is fine but it should be supported by an automated gift workflow that explains to the giver who is a government official, what can be gifted, what is the maximum amount permissible and who needs to approve the gift.
I do realize that there is real value in providing risk-based training. Employees need to understand the “why” behind our policies. But in the end, if we want compliance, we need to provide task-based training, i.e. training that is embedded in the activity that contains the risk.
This way, no one gets their fingers cut off.
The Ethical Leader 