A critical goal of compliance training is to influence employee behavior and prevent compliance violations.
To measure training effectiveness, it is therefore necessary to measure the targeted behavior before and after the training.
If your organization doesn’t know what behavior it is trying to influence, or if it doesn’t try to measure the before-and-after, it’s possible that the training is there simply to check the box.
I once sat through a 90-minute compliance training that consisted of a man in a suit reading bullet points off a screen. I passed the quiz. My colleagues passed the quiz. Nothing changed.
The problem with most compliance training isn’t the content. It’s the assumption that one-size-fits-all delivery will change behavior.
AI is changing that. Imagine training that adapts to your organization’s actual policies, culture, and risk profile — customized at scale, without months of development time.
After 20+ years building ethics programs, I’ve seen what works. Relevance works. Engagement works. Generic doesn’t.
The technology to fix this finally exists.
In a study by Kouchaki and Desai (2015), employees who reflected on the importance of ethical behavior were found to be less likely to engage in unethical behavior.
To create the conditions for such reflection, companies often provide off-the-shelf ethics training. Unfortunately, most employees find the traditional online modules to be relatively boring (and the end-of-module quiz too easy).
Perhaps a more engaging approach is to provide employees with opportunities to discuss real-world ethical dilemmas. A quick look at the morning news should offer several examples of cheating, lying, and stealing. Any supervisor can start a discussion with this phrase: “This just happened at Company X. Could it happen here? If not, why? If yes, how could we respond differently?”
Doing this on a regular basis is sure to align the moral compass of most employees. Give it a shot.
The concept of minimal viable audience (MVA) works well for most businesses. You don’t have to convince everyone that your product is right for them. Instead, you can focus on customers who already want what you have to offer.
When you try to please everyone, you risk creating an average product. This might be why ethics and compliance education, pushed to all employees, is often considered mediocre (and not that effective). What if instead we focused on the MVA?
The MVA for E&C education can often be our supervisors. They usually represent 10-15% of the employee base, having on average 8-10 direct reports each. It’s easier to tailor education for this small group, and it’s easier for them to pass the information on to their direct reports, whom they know well.
I’m not suggesting that all E&C education should be in the form of supervisor-led training (SLT). But I do believe that SLT has its place, and that not enough companies are making a good use of it.
Ukraine is facing criticism today because of its suspected use of petal mines near Russian positions.
Ukraine has been invaded and it has a right to defend itself. It probably feels that it has an obligation to defend its citizens by all means necessary, including using landmines that it promised not to use 25 years ago by treaty. Ukraine is facing a difficult choice: protect its citizens’ lives or uphold a treaty. It’s a difficult choice because Ukraine has to choose between two “rights”. It’s much easier to choose between right and wrong.
Which leads me to ethics training in the corporate world (remember, this is a business ethics blog, not a geopolitical one). Most off-the-shelf training use scenarios where employees must choose between obviously right and wrong solutions: “Should John look the other way when Mike skips a critical safety test on the assembly line, or should he report it?” This type of training might create some awareness but it doesn’t do much in terms of critical thinking.
Surely your company faced a difficult decision in the last few months. It was probably one where the “right thing to do” would impact one stakeholder favorably and another one unfavorably. Why not have leadership share with employees how they made the call? What arguments and consequences did they consider? Why did they land with one course of action over another? This type of transparency generates trust.
And consider using that scenario (or a similar one) in your training. By asking employees to make and justify their own call, you will sharpen their skills for the next tough decision.
Today I asked GPT3 to write a 200-word blog post about business ethics. It wasn’t original but it was surprisingly good.
In a few years, AI will be able to write codes of conduct, corporate policies, training modules, and probably answer many ethics questions from employees.
E&C professionals should embrace this fact and anticipate the changes it will create. The creative aspect of our job is what still remains out of reach for machines.
Do you know how to boost your creativity? GPT3 just served me 9 suggestions.
How much do you spend on online courses to educate your employees about ethics and compliance?
It’s not just the amount you pay to the course provider (internal or external), but also the time spent by the E&C personnel to administer the training platform, and the salaries of your employees while they take the training. In large corporations, the last item can be in the millions of dollars.
At the end of every course, employees should be asked “Will you be able to perform your work more compliantly as a result of taking this course?”
Compare the survey results to the amounts your are paying, and ask yourself if it’s worth it.
P.S.: Most companies don’t want to know.
It was a cold morning yesterday in Buffalo, NY.
I’m sure that the JetBlue passengers were not happy about the 4-hour delay to their Floridian destination.
That is, until they learned that the delay was cause by the detention of their pilot, who had attempted to board the flight to take command while drunk (at more than four times over the FAA’s blood-alcohol limit).
I wonder what would have happened if the TSA agent had not noticed the pilot’s drunkenness. What if a flight attendant had noticed? Would he have spoken up? What if the co-pilot had noticed? Would she have spoken up? I expect they would, given how safety-focused everyone is in the aerospace industry.
Well, not everyone, evidently.
I also wonder if airline employees receive training on how to respond when they see a pilot willing to operate the aircraft under the influence? I wonder, because that type of training is not commonplace in most organizations. We tell employees about the importance of reporting, and we remind them of the channels available, but we rarely tell them exactly how to report. It’s an important gap, especially when the wrongdoing is committed by an intimidating person in authority, like a pilot or an executive.
You tell your employee on March 1 that she will get her bonus check on April 1.
On March 15, she resigns with an effective date of April 15. Do you still pay her bonus? It depends what the bonus is for. Is it a reward for good work or is it a retention tool?
“What is it for?” and “Who is it for?” are key business practices questions. They also apply to E&C programs. Who are you writing this policy for? What is this training for? Who is the audience for this communication?
Often times, we tell employees that these things are for them, when in fact they were created with the regulators or the shareholders in mind. Employees feel the disconnect, and they don’t engage.
There is value in creating E&C programs that are responsive to regulators’ expectations. But if we want them to resonate with employees, we need to be open about who and what they are for.
With every new policy, training, or communication that we are ready to deploy, we need to ask ourselves: “Will our employees now be more likely to speak up if they see a problem?”
If the answer is not a clear yes, our work is not done.
The Ethical Leader 