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February 2017
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TD Magazine

Compliance Training Doesn’t Have to be Boring

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Compliance Training Doesn’t Have to be Boring

A good (dramatic) story that illustrates why compliance is important will accomplish your goals.

You may have heard someone say, "Compliance doesn't make money for the company," but potential costs of failing to comply can make a culture of compliance and the training it takes to support it look like a bargain: BP focused on saving time and money, putting safety on the back burner; Wells Fargo was fined $100 million for focusing on profit with no apparent concern for compliance; workers at the National Security Agency and Booz Allen Hamilton failed to notice or report red flags that could have prevented NSA contractor Harold R. Martin III from stealing immense quantities of classified information and materials. Volkswagen, GM, and Enron all have incurred major fines due to ethical failings. The list is practically endless.

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In many organizations, experienced employees, often members of senior leadership, have heard the compliance training pitch dozens of times and don't feel a need to hear it again. Therefore, they provide the minimum acceptable level of compliance training to "check the box." Some don't realize that compliance training is required because failure to comply can result in catastrophic outcomes. Money, careers, companies, and lives can be at stake if compliance isn't an integral part of corporate culture.

The U.S. government will not do business with companies that don't protect sensitive information they develop and control. Our customers trust BAE Systems to provide advanced solutions uncompromised because the company has a remarkable record of performance in security. Defense Security Services assesses the security posture of defense contractor facilities every year. Possible assessment outcomes are superior, commendable, satisfactory, marginal, and unacceptable. About 40 percent of all cleared contractor facilities receive superior or commendable ratings. During the past five years, more than 90 percent of BAE Systems' facilities have received superior or commendable scores.

Security training provides a consistent message across the enterprise about what we expect of our employees and has played a significant role in establishing a culture of compliance—but it's only part of the picture. We have achieved amazing results because leadership realizes a security failure could damage our customers' trust—even eventually putting us out of business. Thus, leadership supports context-centered training, which takes time, effort, and creativity to develop and present.

Focus on the why

In the earlier examples, compliance rules were ignored, making life "interesting" for corporate executives, employees, and customers. Lessons were learned, but they were lessons that already had been learned and codified in policies and procedures. If our training doesn't reinforce a culture of compliance, motivating employees to comply with policies because "it's just the way we do things here" has been time wasted. When training focuses on content without fully explaining why compliance is important, the lessons are likely to be ignored.

How do we ensure training has the desired impact? Develop objectives toward which every aspect of the lesson must point. In many areas of compliance, our objectives boil down to three things: know the rules, follow the rules, and report instances of noncompliance when you notice them. To engage our learners, we must focus on why compliance is important.

Emotions matter

Adults don't learn well if they're doing it only because it's required. They need to understand the importance of what they're being asked to learn, and we must ensure that our training is, to quote Michael Allen's Guide to e-Learning, "meaningful, memorable, and motivational." If the presenter isn't interested, the students won't care either. In infomercials, spokespeople appear to be rapturously excited about a chamois cloth or caulk because being excited about the product works. So get excited about compliance.

But content alone won't excite anyone. Content must be wrapped in something almost everyone loves: a good story, well presented. An effective story combines content with emotion, capturing attention and cementing content in memory. Begin with a challenge or problem, explore the events surrounding the issue, and then use the story to teach the lesson.

An effective story should be built around characters operating in an environment to which the learners can relate. One way to put your story into context is to create a fictional company to engage; inform and interact; and inspire and empower.

Engage the learner

If last year's training consisted solely of someone reading PowerPoint slides at the employees, you can expect them to show up this year ready to ignore your training and focus on something more interesting, such as checking Facebook. On the other hand, if last year's training was meaningful, memorable, and motivational, your learners are likely to approach this year's session with a positive attitude.

If you build training around a story, they may show up wondering what's going to happen next, which provides instant engagement. Our ongoing story started in 2008 and every year the employees ask, "What's happening this year?" If you don't think a continuing story is a powerful concept, think of how many people show up to see movie sequels.

One approach is to engage by presenting a worst-case scenario. Set your story in an imaginary company in an industry similar to yours. Create a bank, an urgent care facility, or a drilling rig, for example, and populate the fictional business with employees representing employees who work in your enterprise.

Using a bank as an example: George is a midlevel bank manager who only cares about getting the business, ignoring rules when they become inconvenient. Elaine, the bank's CEO, thinks compliance gets in the way of making a profit. Brian, an experienced employee, goes along to get along, so sees nothing, knows nothing, and reports nothing. And Joyce, a new employee, is happy to have a job and is afraid to speak up, even when she sees something totally against what she learned in her orientation.

We begin at the end, showing how George's compliance violations resulted in major fines, which caused the bank to close. The consequences could be revealed by:

  • An audio of George calling his wife to tell her he's being fired and could possibly go to jail because of what he did.
  • An audio of George's co-workers talking about how George's actions are causing the bank to close, costing them their jobs.
  • A breaking news story in a local newspaper.

In each of these cases, the "what's in it for me" is protecting the enterprise to protect their jobs, an outcome most employees would consider to be a positive outcome. With the negative outcome in hand, we can take a look at how the disaster happened.

Inform and interact

One compliance violation is unlikely to result in a significant negative outcome. Severe consequences are usually the result of a series of choices to ignore compliance until bad luck rears its ugly head.

Using our fictional bank, we develop events to combine information and interaction, enabling the learners to observe events that might happen in their workplace and giving them a chance to decide how they would react. We could show George engaging in a series of violations that result in him opening an account drug traffickers were able to use to launder money. In our story, disaster occurred because George ignored compliance policies that would have prevented such a transaction. Following each scenario we'll discuss what happened, why it matters, and what should have been done in response to the violations.

Once we have a solid environment for our story, we can use our fictional entity over multiple years to reinforce learning from various aspects. The first year we look at what happened, how George's co-workers reacted, and discuss what should have been done to prevent disaster. In year two (dramatic license is a wonderful thing), we could put George's co-workers on trial for negligence, role-play testimony about the events observed the previous year, then address compliance as we debrief their testimony.

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In the third year, we could look at events from the point of view of the narcotics traffickers, thinking about what they would be searching for in an effort to find banks they could use for their purposes, especially how they would go about identifying potentially vulnerable individuals and enterprises. Year four could examine the entire sequence of events narrated from jail by George, who now has plenty of time on his hands because he knowingly allowed the money launderers to operate accounts he had opened. When done well, learners come to each year's training wondering, "What's going to happen this year?" Talk about having a leg up in getting employees engaged in learning.

Inspire and empower

We've shared content and enabled our students to put their knowledge to use in scenarios they could encounter. But if we don't tell the learners what they're expected to do, explain how to do it, and give them a compelling reason to act, we've wasted everyone's time. The compelling reason can't be "Because we told you so." We must demonstrate that it's in the best interest of the learner to comply with the rules and report violations.

In our scenarios, the learners observed violations that led to disaster. Ask for action by having learners identify how disaster could have been prevented—if even one of George's co-workers had reported violations, the outcome would have been positive. An alternative outcome in which the bank had record profits and everyone received a bonus because there were no compliance violations provides two "what's in it for me" key points. We don't just show them how to avoid disaster; we also give them a positive reason to comply and to report violations.

After giving them reasons to report violations, you also must show employees how to make reports. Identify the compliance officer to whom they would be expected to report and provide a tool for anonymous reporting, such as a hotline. Remind employees that the earlier issues are reported, the better chance we have of avoiding disaster.

If compliance isn't part of how we do business every day, our customers will notice, will lose trust in the institution, and will find another organization with which to do business.

Three Tips for Making a Compliance Training Class Engaging

Bring passion. If you're not interested in the training program you're presenting, no one else will be interested. It's not easy to be excited about facts, so help yourself by wrapping your facts in scenarios that relate to compliance. If the scenarios are gripping, you can provide drama and humor to enliven your presentation. Also, practice before you go in front of a class. A video camera is a low-cost way to see how you'll look to the class.

Ask questions. After each scenario, challenge the class to answer three questions: What happened? Why does it matter? What should be done about it? After you ask the question, wait for someone to answer. They know the answers, but if you answer the questions for them, learners lose the chance to confirm and reinforce their knowledge.

Reward participation. Everyone loves to win prizes, but you don't need a major budget to provide the chance to win. A deck of cards is an inexpensive way to encourage participation. Put 12 to 15 cards in your pocket and give a card to the person who answers a question. In that way one prize (which can be very inexpensive) per session will give numerous people a chance to feel like winners.

About the Author

Steve Rients has been manager of security training for BAE Systems since November 2005. He is a Certified Professional in Learning and Performance (CPLP) and a Certified Protection Professional (CPP).

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