Compliance and ethics training for global companies: An 8-point checklist
June 20, 2018
Developing and managing an effective global compliance and ethics (C&E) training program can be a daunting task. Understanding the rules and regulations that apply, and potentially may apply, to the company’s business operations, in one or more countries is the first priority. Then training programs must be established and conducted for all relevant employees with accurate certification procedures to provide an auditable record.
While there are many requirements that are applicable regardless of where one’s business is conducted, every country has unique requirements, and failure to fully understand country-specific requirements can have legal and criminal consequences, both to the organization and to individuals throughout the business.
I have found in my more than 20 years’ experience working with global companies there is an eight point checklist for evaluating your C&E program:
- Make training unique to your company’s needs and to the needs of your employees. Where C&E training is mandatory in order to satisfy specific regulatory requirements, such as the Sarbanes Oxley Act, financial services or anti-bribery statutes, materials and training should be delivered in local languages wherever possible. English-only materials create the risk of unnecessary and potentially litigious misunderstandings, even if it is the main business language of the company. Travelport currently operates in more than 180 countries around the world and produces training materials in seven languages (English, Chinese, French, German, Italian, Japanese and Spanish
- Conduct face-to-face training whenever possible. I have found no other format to beat face-to-face training. Having local senior management involved gives the audience the reassurance that leadership values in person training as a priority and is resourcing it appropriately.
- Global training must adhere to global standards, yet also must accommodate local law variance. C&E policy development, materials and training at Travelport are created to global best practice standards, then adapted to accommodate local variances in law. This allows all employees to understand collectively how the company responds to trans-national laws, such as the U.K. and U.S. anti-corruption laws, which apply to company activities regardless of where violations may occur in the world.
- Changing legal requirements requires constant vigilance to keep C&E training content current and fresh. Changes in the law, along with the introduction of relevant new laws, provide both challenges and opportunities for training across jurisdictions. Two examples are the U.K. Modern Slavery Act, and the EU General Data Protection Regulation (GDPR). The work involved in keeping up to date and including new subjects in each year’s mandatory training not only is necessary, but it also keeps C&E content fresh and relevant to employees.
- Build company-wide relationships to stay on top of changes in the business. Developing relationships as a trusted business partner with colleagues throughout the company is an essential part of keeping up to date with not only changes in the business, but also to issues that are evident in the business.Establishing these relationships is critical to successful C&E training.
- Online training provides proof of competency. Carefully structured online training can address when, where and how mandatory C&E completions are tracked. At Travelport we ask each employee, “Do you know and understand the subject of the training delivered, and do you adhere to Travelport policies in your work?” Online training provides proof that an employee has completed the training and certified they adhere to the policies.
- Be cognizant of the time required to produce and deliver training in a global environment. Tailored training to meet the unique needs of a company takes longer to produce than generic “off the shelf” training from a services provider. (And, in my experience it takes as long, if not longer, to tailor the training of service providers!) But tailoring training content for your company is its strength, and to me there is substantial value in spending the extra time learning in detail about the business, new laws, issues with policies and procedures that enables the production of relevant and maybe even interesting training.
- C&E training is a team effort. Developing and managing best in class training requires more than just a qualified C&E professional. Colleagues throughout the enterprise have a key role to play. These include subject matter experts in different areas of the business, including: Legal; Human Resources, Internal Communications, Finance, and Cyber Security and Risk Management. Make no mistake, it takes a corporate village to create and implement a successful, engaging and effective C&E training program.