What if your employees had a choice?
What if they could choose to read your code of conduct or not to read it. To take the online training or not to take it. To participate in an investigation or not to participate.
What would you do differently if this were the case?
HT to Seth Godin.
Providing training is like giving advice.
If it’s for a specific person, it’s likely to land. If it’s for a group, it’s likely to miss the mark for a few people.
That doesn’t mean we shouldn’t create training materials for large groups. When we do, we simply need to create a space for discussion between the trainer and the trainees.
What of online training? Well, it can be a two-step process. First, the employees complete the training, then they discuss as a group.
The first step shows you have provided the training. The second shows that you cared about the learning.
You compliance training doesn’t have to be fun. It doesn’t have to be entertaining. Or popular.
It can be, but it doesn’t have to.
If you assume that your employees want to do the right thing, then what your training must do is help them do their job compliantly.
An animated video about the elements of antitrust violations can be entertaining, but the learnings will have faded 6 months later when your sales rep is about to attend a trade show. What she’ll really need at that moment is a boring job aid like a simple checklist of what she must do before, during and after the trade show (e.g. submit the agenda and the minutes to Legal, make a “noisy exit”, etc.).
Just-in-time training. Task-based training. That’s what most front-line employees need.
Think about the approach of safety professionals. Next to every doorway leading onto the shop floor, there is a sign asking employees to wear safety goggles and a bin containing such goggles. No one is simply relying on the safety video that was shown to the employees on their first day on the job.
So why don’t we do the same for legal risks? Why do we continue to rely on once-a-year videos and certifications?
It’s a big task, of course. But we can start small:
Then move back up the list and address the other tasks. Then the other groups. Then the other locations. Then select another risk and go back down the list.
It’ll take time but you will be making real progress.
Imagine a world where we don’t put stop signs or traffic lights at dangerous intersections.
Instead, we provide training to all students entering high school, telling them where the dangerous intersections are, hoping they will remember when they first take the wheel a few years later.
Sounds ridiculous?
Yet, many companies train their new employees on antitrust or corruption risks months or years before these employees will attend a trade show or interact with a government customers. Wouldn’t it be better for the training to be provided just before every trade show or customer meeting – as if they were approaching a dangerous intersection?
According to this article, most homebuyers are not warned about the new flood or wildfire risk caused by climate change. They know a lot about their new home: quality of schools, access to public transportation, and presence of lead paint. But they don’t know about the rising risks associated with climate change, mostly because the law doesn’t require disclosure.
Which got me thinking: are companies adapting their new employee training and onboarding process to account for the new risks associated with the pandemic and social justice?
Is yours?
Try the test below:
How difficult was that?
That’s the feeling employees get when they complete the quiz at the end of most online ethics training. They listen to the story of a fictional employee who overheard a colleague say he was willing to pay a bribe to get a contract and the quiz reads “What should Joe do? (A) Report what he heard to Legal; or (B) Nothing because he’s not personally involved in the wrongdoing.”
I’m exaggerating a bit for effect, but not that much.
That kind of training does not help employees recognize ethical dilemmas, does not show them how to take action, and thus is a huge waste of your budget.
Consider instead a live session between a manager and her direct reports (video call is great). Change the script so that it’s not clear that what Joe overhears is a promise to pay a bribe. Make the conversation about what Joe should do and how he should do it. Then shift the discussion and talk about how employees in your company, not Joe’s fictional company, should react in this situation. Who should they talk to? How can they reach them? What should they say?
The purpose of ethics and compliance training is to help employees be compliant and ethical at work. Is yours achieving these goals?
Which is more effective? A business school that offers a separate business ethics class or one where business ethics is weaved into every topic of every class?
The answer is obvious.
Similarly, an organization that provides an annual business ethics training session is not nearly as strong as one where leaders share the ethical considerations of every decision.
As a leader, you will make at least one decision today. That decision will either be in line with your organization’s values or it won’t. Talk about it with your team.
And then do it again tomorrow.
There are different ways to train employees. Depending on the risk we face, some ways are better than others. Here are a few options (among many others):
I am currently creating a training module on the importance of trust in the workplace.
A colleague of mine suggested that we reverse the usual order of these modules. Instead of explaining what trust is and then testing our employees’ understanding through scenarios, she recommended that we let them struggle with the scenarios first.
It’s a simple idea and not a novel one. Yet, I haven’t seen it applied to E&C training. We typically give employees dozens of slides on a specific topic and then quiz them. In other words, we give them the answers first and see if they can remember them. It’s not the best form of learning. We see proof of this when employees violate rules they were trained on because, one year later, they don’t remember the training.
I look forward to trying this new approach. As a learner, I would prefer to discover rather than to memorize.
HT to Seth Godin
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 