Every year, millions of employees take ethics or compliance training. Whether it is called “ethics training” or “compliance training,” its purpose is the same—to acquaint employees with a set of rules that are supposed to guide their actions. In highly regulated industries, such as health care, defense contracting, and financial services, the training often is mandatory for all employees. While you might expect a significant impact from such a massive training effort, we are hardly seeing a renaissance in business ethics. In fact, data from the Ethics-Compliance Survey administered by the Council of Ethical Organizations to hundreds of organizations since 1986 shows little correlation between ethics-compliance training and the ethical climate of an organization. So how do we get more bang for the ethics-compliance training buck?
Most ethics-compliance training is designed without input from training professionals. It is designed by lawyers, auditors, or others with assumed mastery of the subject matter. The argument for excluding input from training professionals is that the content is too specific or technical to be handled by anyone not schooled in compliance. No one looks at the other side of the equation, which states that individuals with no expertise in training cannot be expected to design an effective training program. The result is that ethics-compliance training is often technically accurate, but otherwise ineffective.
An excellent opportunity to build an organizational culture of ethics and compliance is being squandered. However, three simple steps can make ethics-compliance training more effective:
1. Have rigorous behavioral objectives. Most trainings have a behavioral objective, but few have behavioral objectives that go beyond merely being able to say that the training was completed. It may appear that we have already stated the objective of ethics-compliance training—to acquaint employees with a set of rules intended to guide their behavior. But this is a behavioral objective only if we assume that awareness of a set of rules by itself changes behavior. Common sense tells us that knowing the speed limit is one thing, and obeying it is quite another.
One behavioral objective for any ethics-compliance training program is that employees be more willing to report ethics-compliance concerns through internal reporting channels. You will know that you have achieved this behavioral goal if the volume of reports through the organization’s ethics hotline increases after the training—a behavioral measure.
You would expect years of ethics-compliance training to increase the likelihood of employees following the rules covered in the training. Audits in ethics-compliance-sensitive areas will reveal whether behaviors have changed. While many factors may complicate the outcome of audits, you would expect ethics-compliance training to somewhat reduce noncompliant conduct—another behavioral measure.
2. Build your training around realistic situations. While you may want people to remember and follow certain rules, there are better ways to accomplish this than simply stating a lot of rules. The best approach is to use realistic situations that illustrate application of the rules in the areas of most concern to the organization.
Many illustrations used in ethics-compliance training are so simplistic that they insult participants’ intelligence. If you want people to pay attention to the situations, and the rules that apply to them, present situations within the participants’ experience. Choose situations you might not know how to handle without knowledge of the applicable rule.
An example: Most hospitals prohibit staff from accepting gifts from patients. The point is to avoid the appearance that patients with the means to reward caregivers receive better treatment than other patients. But suppose a patient has knitted a shawl including the name of her caregiver during her hospital stay. Is it wrong for the caregiver to accept this gift, especially since it is offered when the patient is being discharged?
Different organizations call this situation in different ways. Most will say that a personalized gift of limited monetary value can be accepted, since refusing it insults the patient. But however you call this situation, it is likely that many training participants will remember it and remember that there is a general rule prohibiting gifts from patients. Even if they don’t remember the exact rule, they will remember that this is a situation in which they should consult policy or ask a supervisor—the behaviors we are seeking.
Using realistic scenarios also allows you to customize your training to fit specific audiences. Scenarios that fit the experience of most employees may not be suitable for your executive team. You also may want to vary the illustrations for types of employees—such as those who work on government contracts as opposed to those who do exclusively commercial work. You can keep the framework of your training the same while plugging in different illustrations for specific audiences.
3. Be sure the training has take-away value for attendees. When you use one or two hours of every employee’s time every year, there should be identifiable take-away value to the training. If there is no identifiable take-away value, participants likely will conclude that they were subjected to the training to allow someone to check a box. They may even conclude that the organization did something wrong and is subjecting employees to ethics-compliance training as penance.
The design problem is that the take-away value to the organization—attendees are more likely to follow certain rules—is not likely to be viewed as the take-away value by attendees. There are several ways to remedy this. If participants are better informed about how to handle situations they confront, this counts as take-away value. Another approach is to offer a decision tool for attendees to use when they face challenging situations. Introduce the tool early in the training so participants can use the tool to help address the scenarios.
These three steps will make your organization’s ethics-compliance training more meaningful to participants while also providing value to the organization. There are many other ways to add value to ethics-compliance training. Whatever approach you take, the test should be the same: Will the training influence the behavior of participants in accordance with the goals of the training? Unless your training passes this test, it is unlikely to help the organization build a culture of ethics and compliance.
Mark Pastin (www.markpastin.com) is an ethics thought leader, ethics consultant, and keynote speaker. He’s the CEO of the Council of Ethical Organizations, a nonprofit dedicated to promoting ethics in business and government. A Harvard-educated ethicist who’s received grants from the National Science Foundation and the National Endowment for the Humanities, he’s published more than 100 articles and written a book, “Make an Ethical Difference: Tools for Better Action” (Berrett-Koehler).
