Whitepaper: Of Culture, Code and Compliance


Code of Conduct:
Content and communications

By Edward Schweitzer and James McDonough

The need to set standards of conduct that facilitate legal compliance and risk avoidance is an organizational imperative which any Code of Conduct must address. Yet, a purely defensive, compliance-based approach to integrity and risk management has been shown to have its limitations.

Increasing public disapproval of corporate conduct that is questionable is causing some companies to think more about how they achieve business goals, as well as what they do. With this generally comes greater focus in companies’ codes on ethics and other values-based standards that are not actually mandated by laws and regulations.

As companies figure out how best to reflect and address such concerns in the context of their own business environment, the code development and review process must necessarily acknowledge questions of reputation and stakeholder trust, and the underlying issues of organizational identity and culture. Thus it has become necessary to consider what a code communications campaign can and should convey about the nature of the organization, what the organization stands for and its aspirations.

Whatever the approach, a company should an established procedure for keeping its code relevant, accessible and fresh so that it remains a ‘living’ embodiment of the organization;s commitment to doing business ethically and in compliance with the law. Following are some of the ‘best practices’ we deem critical to the success of any code program and its communications to stakeholders.

Conduct project-based investigation early in the process

Engage not only the project team, but leaders and employees early in the process. Solicit their interests, attitudes and opinions (IAOs) to organizational values, compliance, training, and preferred communication channels. By leveraging an ‘evidence-based’ approach to program design, company’s can deliver actionable insights to help grow a Culture of Compliance – one that supports organizational goals, as well as employee engagement. As an example, I think back to our research and strategy presentation with American Express (AXP) when, upon presentation of our insights, the Account Director from the online training company was asked if they would have approached the compliance training any differently. Their response was, “Absolutely. We would have done everything differently.”  A little information is a powerful thing if used well.

Reassess organizational values and link to compliance and ethics

This has become one of the  cornerstones for our approach to compliance programs and training. Linking compliance training to a company’s values is not only good business – it provides the “what’s in it for me” (WIIFM) factor for employees. A clear line of sight between a company’s values and Compliance training is the quickest way to help employees understand their personal and moral obligation to the company’s success.

Leaders must model behavior

A recent study from the W.P Carey School of Business Management in China found that employee loyalty was directly related to whether a leader’s personal social values matched his or her outward statements.
We heard similar comments in a study we recently finished for GlaxoSmithKline (GSK). Employees not only desired, but felt it was imperative for the executive management team to initiate training. In our interview with GSK CEO Andrew Witty, he reinforced this belief. While he believed that the program we were developing for the org must be owned by Legal, he felt that employees would embrace the program unconditionally if the c-suite were the ones to launch the program and take training first. In the case of GSK, we supported leadership modeling (and speaking consistently of) the program with written case studies, easy to use resources, talking points, and an online toolkit (similar to AXP). All of these assets allowed leaders, managers and supervisors a consistent, and easy to deploy, framework for training and communications.

Solicit inter-departmental support and collaboration

As part of the investigation phase we uncover the most productive methods and channels to deliver training and communications within each organizations culture. Companies and their corporate cultures are unique – each has a different method for communicating with their employees and understands what method works best for their various lines of business and departments. In the case of AXP we quickly identified the most effective and efficient communications methods through inter-departmental interviews with the corporate communications and brand teams.

Deliver training and messaging ‘middle-down’, as well as ‘top-down’

While employees want to believe their leaders are the vanguard of compliance training, we have found that they want communications and training delivered to them by their direct managers. Employees feel far more engaged when they have a direct connection to a training program. They feel freer to ask questions, and extend their learning when training is part of a ‘team initiative’. A team approach to learning also allows trainers an opportunity to create a ‘safe-haven’ for Q&A, follow-up and reinforcement.

Link compliance training to other on-going initiatives

Linking compliance tTraining with another initiatives that either already has widespread acceptance or a prominent advocate (CEO, Chief Legal Counsel, CCO, etc.) provides weight to new or refreshed training program. By piggy-backing on another on-going initiative, it is easier to quickly spread the gospel of compliance as well as the potential to cross-purpose budgets – saving time and money.

Support various learning styles

Support various learning styles – but do it with style. Standard training programs yield standard results. Employees want to feel that they matter. Allow employees an opportunity to select a mode of training that supports how they learn, or at a time of their choosing. Face-to-face, has yielded the best results for busy executives and e-learning is a cost-effective method for reaching large groups of employees – but a ‘blended’ method can yield better results. It all comes down to segmenting the audience based on any number of criteria, i.e., F2F for execs, leaders and high risk employees. Managers can be trained to deliver F2F with small groups and cross-functional teams. E-learning for larger groups works well, but can have a greater impact if follow-up with a F2F Q&A session, or a follow-up survey.
And finally, leverage the power of multiple media, i.e., live action video and animation, case studies, scenarios, role-playing, recurring ‘refreshers’, etc. to engage employees in a manner that supports how they learn best.

Make training interactive, real and human.

Training and Compliance communications have always been considered a ‘check the box’ proposition by employees. Positioning training as an interactive experience makes it more memorable and helps to ensure it imprints on employees sub-conscious. Real-world examples gathered during the initial research phase can bring training ‘home’ for employees.  I.e., In our work with Altria we discovered that the largest segment of the company (60%) was non-salaried and employees, on the line and in the field. We could not message to these employees the same way as we did with the rest of the org. Not only were they difficult to reach (unconnected with technology and impossible to take off the floor), but they were fearful and suspect of messages from corporate. Two days of interviews with representatives of this group allowed us to uncover not only how to speak to them, in their own vernacular (much different than salaried employees), but more importantly, where we could reach them.

Utilize and leverage existing channels

Innovative delivery of training and communications has the opportunity to create unique and compelling results – but the reality is, not every training program needs to recreate the wheel. With a little investigation there are numerous existing channels within a company to deliver training and communications to employees that reach them where they already are. This approach saves the company time and money resulting in a higher ROI.

Field test pilot components to representative audiences

A pilot is de rigueur for any training program, but ‘rapid-prototyping’ elements of a training program can yield powerful insights before an organization spends inordinate amounts of money on the design of an entire program.
Not really a best practice, but more of an opportunity – looking at how web developers refine their products through usability testing and quickly prototyping preliminary components of a training program allows Compliance an opportunity to ‘beta test’ its training program to a representative audience. Findsings from these ‘field tests’ allow instructional design teams to enhance what is working, and redesign what is not.
Our experience in usability testing (with company’s such as Sally Mae, Centocor and Novo Nordisk and ) have allowed us to quickly respond to user needs and requirements, saving our clients time and money on costly alterations and revisions.

Branding is a part of the process

We cannot discount the fact that for any training program to be successful, its value to the trainee and the company must be made clear. Branded communications not only spread the word about the need for Compliance training, but most importantly the value and the benefit to the employee. Branding cuts through the noise of company communications to deliver a promise to employees. Branded communications allow a training program to differentiate itself from the plethora of communications employees receive and helps to create consistency in messaging which helps to create trust in the program.

Develop a launch strategy and then drive it home

Coordinate enterprise training so new launches are paced out. Launching consecutive programs causes confusion with employees, as they may ‘believe’ they have already taken the training, when in reality it may have been another program. Allow time for the training to reach near completion, and then follow-up with accelerated messaging. Achieving the last 10% is difficult. Developing a strategy to reach new-hires as well to complete the cycle is an easy method to maintain compliance.

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