Excellence in Training

In this episode of Excellence in Training, Shawn Rogers provides some thoughts on the veiled land of –the future of compliance training.

Highlights include:

1.Compliance Training will be More Respectful of the Learner

2. Compliance Training Abuse” will Stop 

3. Compliance Training will become More Relevant to Learner Roles

4. Compliance Training becomes More Integrated into Business Processes

5. Compliance Training becomes More “Bottom-Up” Driven than “Top Down” Driven 

Disclaimer-As a company, GM uses many training vendors. GM’s compliance function primarily uses two vendors. Rogers has worked with other good vendors that currently do not work with GM. Rogers is not promoting any specific vendors, nor is he disparaging any specific vendors in this podcast. And, of course, these opinions are Roger’s alone and opinions that  developed over almost 15 years. He is not speaking on behalf of GM in any way.

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In this episode of Excellence in Training, Shawn Rogers provides some thoughts on how training frequency and the amount of training can positively or negatively impact an overall training strategy.

It be fantastic if we viewed compliance training in the same way instead of giving an hour-long course on a topic they have heard before, what if instead employees received a 10-minute “refresher” training just to maintain their awareness and get the message that they should constantly be vigilant?

There are some compliance topics that are so important to a company that training needs to be required fairly regularly, maybe even annually. For instance, at GM, we have decided that it is important to provide reminder training annually on a few topics:The importance of our Code of ConductThe importance of speaking up when a concern is observed, and how to report the concernAn understanding of the company’s non-retaliation policyThe importance of workplace and vehicle safetyThe requirement to disclose conflicts of interest.At GM, we are moving towards a less frequent repetition of lengthy training courses for our current employees, and more frequent “refresher” or “reminder” training modules that keep the risk top-of-mind without assuming that lengthy courses need to be repeated every year. It is a very common sense and defensible approach to compliance training.

New GM employees are required to take more detailed courses during their first year so that they are exposed to the key risks in detail. After that, full-length courses are staggered in a three-year interval so we can keep the courses updated and to avoid over-training. 

Disclaimer-As a company, GM uses many training vendors. GM’s compliance function primarily uses two vendors. Rogers has worked with other good vendors that currently do not work with GM. Rogers is not promoting any specific vendors, nor is he disparaging any specific vendors in this podcast. And, of course, these opinions are Roger’s alone and opinions that  developed over almost 15 years. He is not speaking on behalf of GM in any way.

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In this episode of Excellence in Training, Shawn Rogers provides some of this thoughts on measuring training effectiveness.

To measure the effectiveness of a compliance training program, you can’t come up with a metric that measures how many violations it prevented. Everybody knows intuitively that training helps prevent compliance violations. Again, that measurement is too far removed from the purpose of the compliance training program. However, it would be a good metric for the overall training program if you could figure out how to do it.

But how often do you see companies reporting the number of classes that were delivered? Or how many hours of compliance training were completed? It happens all the time. It could be a completely accurate statistic. It could be a measure of compliance program efficiency. It could be an indicator of an active compliance training program. But it in no way shows if the compliance training is effective.

But there are ways to measure training effectiveness. You can show that the training was aligned to the company’s risk profile. With user surveys and focus groups you can measure whether the learners feel that the training is applicable to their role and you can measure user satisfaction. You can ask learners to give examples of how they have changed the way they do their jobs.

Why don’t companies do a better job in measuring the effectiveness of compliance training? Because it’s very challenging to do. But there are ways to do it. Shawn conclude with one of his current ‘most favorites’ implemented at GM this year.

At GM there is a cybersecurity course that explains how to avoid phishing email scams. It is required of all employees that have a GM email account. To measure how effective the training was, the IT function came up with a method of sending out emails to random batches of employees that should have been recognized as phishing emails if they had paid attention to the training. If the employee recognized that the email was suspicious and clicked on the “Report Phishing” button, they were congratulated on reporting the email as suspicious. However, if they clicked on the link in the email, the IT team knew that the training had not met its objective. And, those employees that clicked on the link were kindly informed that they had failed the competency test and were provided with immediate feedback on how to avoid phishing scams.

Disclaimer-As a company, GM uses many training vendors. GM’s compliance function primarily uses two vendors. Rogers has worked with other good vendors that currently do not work with GM. Rogers is not promoting any specific vendors, nor is he disparaging any specific vendors in this podcast. And, of course, these opinions are Roger’s alone and opinions that  developed over almost 15 years. He is not speaking on behalf of GM in any way.

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In this episode of Excellence in Training, Shawn Rogers provides some of this thoughts on working with training vendors. Shawn adds this disclaimer-As a company, GM uses many training vendors. Our compliance function primarily uses two vendors. He has worked with other good vendors that currently do not work with GM. He is not promoting any specific vendors, nor is he disparaging any specific vendors in this podcast. And, of course, these opinions are Shawn’s alone and opinions that  developed over almost 15 years. He is not speaking on behalf of GM in any way.

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In this episode of Excellence in Training, Tom Fox and Shawn Rogers consider just how does a company create a comprehensive compliance training program that covers its complete risk profile? Many large company faces many legal and regulatory risks, and often many of those risks are “owned” by organizations that are outside of the compliance function. This is a huge challenge for a company the size of GM. But I think this is probably faced by most companies. How do you create a risk-based compliance training program that addresses ALL of a company’s legal and regulatory risks, including the risks that are “owned” outside of the established compliance function? One possible approach is to establish a corporate compliance training governance committee that looks at the company’s overall risk profile and builds a cross-functional and comprehensive multi-year training plan that effectively addresses all of the risks in a company’s risk portfolio. This is what GM has tried to do. 

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Design objectives are the desired characteristics you want your program to exhibit once it is built out. Design objectives help you decide what your program elements should look like. 

Before you go to the car dealer you probably know the characteristics you want in the vehicle you are looking for.  Failing to think about your design objectives is like going to an automobile dealer not knowing if you want a truck, an SUV, a crossover, or a sedan. All are great vehicles and all do certain things very well, but not all will meet your specific needs at a given time. I didn’t need a four-wheel drive vehicle when I lived in Texas. But I certainly want that for driving in Michigan. Your decision on your vehicle will depend on what you want it to do and how you want it to perform at a given time.

Your company might value other things besides those I’ve talked about in this podcast. But if you think about your design objectives early in the planning phase, it will make your program implementation easier. It is also helpful to have these design objectives in hand before you start talking to the vendors who want your training business. You’ll be more likely to find a vendor that will meet your requirements if you go into the discussions with a vision of what you want them to provide.

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In this episode of Excellence in Training, Shawn Rogers and I consider how you should envision your training.

 Shawn begins his journey with the famous book, The Seven Habits of Highly Effective People, where Stephen R. Covey said, “All things are created twice. There’s a mental or first creation, and a physical or second creation to all things. Take the construction of a home, for example. You create it in every detail before you ever hammer the first nail into place. . . Then you reduce it to blueprint and develop construction plans. . . Begin with the end in mind. ”

This principle applies to creating a compliance training program. A common mistake is jumping right to the question if which courses you want and how to deploy them. However, there are several things you need to think about before you start building the program.

Here are the steps we followed at GM as we envisioned what our compliance training should look like:Decide on the program’s guiding principlesEstablish program design objectivesDevelop a style guide or set of course standardsDetermine the exact risks that will be addressed by the training programSet up a governance process to ensure stakeholder alignment, approve the program design, approve the budget, and monitor effectiveness.In Covey’s terms, these activities resulted in the blueprint — or the  “first creation” —  of our compliance training program. We did all of these before we selected our vendor and started building our training courses.

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How do you organize and formulate the requirements for your compliance training? Join us on this episode of Excellence in Training as we talk about how to begin building a compliance program that is both risk-based and tailored to your organization.

Performing an evaluation

You will probably already have some tools, documents, and resources you can go to in your organization that will give you a good idea as to where you need to go. You can also often go to other companies that are similarly situated, find out what they’re doing well, and leverage off of that.

What you’re also going to want to do is talk to your Chief Compliance Officer and ask them: what keeps you awake at night? What are the gaps that training could help address?

Then look practically and check to see if there are any legal requirements that are being mandated upon your company, and if there are any company policies in play.

Finally, find out what the other drivers are that are mandating you to build a compliance training function. Have you had a recent compliance phase? What did you learn from that, and were there any skill, knowledge, or behavioral gaps that you want to address through your training program?

Once you synthesize all this, you’ll see trends and risks that need to be emphasized to help you figure out what your program should ultimately look like.

No one size fits all solution

Build your program to address your specific issues instead of pulling out off-the-shelf compliance courses. Define the risks that are particular to your organization, and then tailor the solution by making decisions on how you’re going to deploy the training, to what audiences, with what frequency, and so forth, to cover all your bases. 

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When creating a new training program, where and how do you start? Join us on this episode of Excellence in Training as we take up the topic of getting your bearings. Here are some questions to ask.

Where are we at with the training functions today?

Look at the training that’s currently in place. Is it good training? What’s wrong with it? What’s strong about it? What do you already have that you can leverage? And how would you improve it? 

What is the risk environment?

If you don’t have a comprehensive risk assessment available, you can talk with the people in the company who have been around for a long time. They’re going to know what the risks are with 95% – 99% accuracy. Map out these risks, even if it takes a month or two, and develop connections with the system level people, the subject matter experts, the key stakeholders, and find out who is in what place in your current situation. 

Sean shares about the “Bubble Chart” he ended up creating for GM, with 16 different influencing factors, and how, through this process, he was able to make connections with people across different departments. Just as important as identifying what should go into the program is identifying who should be involved and contributing to it.

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Welcome to Excellence in Training hosted by Sean Rogers. Sean is the Lead Counsel for Compliance Training and Communications at General Motors and builds out the company’s compliance and training functions. In this podcast series, Sean will provide compliance practitioners ideas about training, what works and doesn’t work, and how he’s been able to develop a best practices and best in class training program at General Motors. 

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