Creating a strong compliance program is only half the battle.
By Kristin Caplice
For those involved with corporate compliance and employee training programs, the hardest challenges are how to engage employees and get your messages to stick.
Here are the top ten things that have worked for us at Analog Devices:
- Put Some Weight Behind It. Everyone talks about “tone at the top” but it’s critical to demonstrate to your employees how important your compliance program is to your executives and Board of Directors. If they don’t take it seriously, why should your employees? Before we launched our compliance training program, we filmed our executives talking about the importance of the program and circulated the video to all employees.
- Involve Your Employees. Before you launch a training module, solicit input from the employees you are seeking to train. Ask questions about the types of situations they face. Then customize your course content to include these fact patterns and provide practical guidance they can really use.
- Use a Multi-Pronged Approach. Be sensitive to saturating employees with dry course content or repetitive training methods. Spice it up with a variety of different training components, like online training, in-person training, and webinars. Rotate the subject matter of your training modules in a manner that seems relevant given what is occurring in the world around you. We launched our latest insider trading course after the Galleon scandal broke, which helped us demonstrate in a very real way why the topic is so important.
- Avoid Training Fatigue. The quickest way to get employees to tune out your training is to launch content that is irrelevant to them. If your manufacturing employees don’t have any interactions with outside third parties in the course of their jobs, maybe they don’t need to take your course on fair competition practices. Communicating about what employees can expect can also reduce the potential for frustration with the frequency of your training modules. We publish a calendar of our upcoming courses.
- Make it Practical. Make practical tools available to employees. We post ethics FAQs on our intranet and update them frequently. The FAQs contain actual ethical dilemmas our employees have faced and our suggestions for how to deal with them. If you have a global workforce, translating your course material demonstrates that you are trying your best to make your training program practical. Your employees will appreciate the effort.
- Make it Easy to Find. Employees should not have to work to find information about your program. We created a compliance page on our intranet that contains our policies, links to our training courses and archived webinars, cartoons featuring particular ethics topics, FAQs, checklists and information about our anonymous ethics hotline.
- Be Creative. Think of creative ways to improve participation in your training programs. One thing that worked for us is to publish our course completion rate by department. This generates friendly competition because, for example, Finance definitely does not want to be outdone by Purchasing.
- Share Success Stories. Don’t just launch your courses and move on. If something positive happens as a result of your compliance program, share it. This will help reinforce that the program is not just a check the box exercise; it has tangible payoffs. One of our facilities recently received recognition from the Massachusetts EPA for its leadership in toxic use reductions. We immediately shared that good news with all employees as an example of how their hard work pays off.
- Poll Employees for Feedback. Polling can be a good source of information to help you target your training efforts. We were curious how comfortable our employees felt about using our anonymous ethics hotline, so we conducted a poll. What we found out was instructive. A common reason given for not using the hotline was that people were not confident it was actually anonymous. In response, we published a detailed description of how the hotline process worked to demonstrate how we could not possibly know the employee’s identity.
- Demonstrate Your Approachability. Don’t sit in your office waiting for people to come to you with questions. Walk around and ask employees what they are doing and what things they grapple with. Show them you’re approachable, helpful, and won’t bite if they come to you with an issue.
Kristin Caplice is Assistant General Counsel at Analog Devices where she is responsible for corporate governance, compliance, and SEC reporting.