Courtesy of The Broadcat
Ricardo Pellafone (ricardo@thebroadcat.com)
There’s a lot of talk about simplicity in compliance lately. (See here, here, and here for examples.)
And that’s a good thing. Especially when the DOJ’s compliance expert is saying stuff like this:
[When judging if a company has a “real” compliance program] I also look to see how the most front-line workers understand their jobs: Does the clerk in the accounts-payable room understand his job to be processing payments as quickly as he can, or does he understand that he is supposed to keep an eye on certain things and escalate issues he identifies? Does the new salesperson understand her job to be making the deal at all costs, or does she understand that there are boundaries?
She’s describing a simple problem—one that’s solved by giving simple training that tells employees what to do.
But developing that kind of training isn’t easy. If it feels that way, there’s a good chance that you’re not actually making simple training, just giving a nice high-level overview of the law.
And that matters. Because the difference between making your training simple and making it high-level is like the difference between a dolphin and a shark. At a glance, they can look pretty similar—but one of them will come back to bite you.
So, here’s how to tell them apart.
Simple training makes it easier for employees to do their jobs compliantly by tying legal standards to what employees actually do at a task level. To make this kind of training, you have to know (1) the law, (2) how your business works, (3) how your processes work, and (4) what key employees do at a task level.
Simple training sounds like “here’s how we review an invoice for red flags” and “here’s how we ship prototypes across borders.” It answers the question “what am I supposed to do?”
High-level training, on the other hand, just does a good job of explaining the law. It sounds like “four things you need to know about anti-corruption” or “three key points of trade compliance.” It answers the question “what’s the standard?”
High-level stuff can be really helpful to you as a compliance professional that needs to stay up on legal standards, but it doesn’t make things much easier for your employees—because it doesn’t bridge the gap between the law and what they actually do.
Of course, in an ideal world, your employees would make that connection on their own. But if that actually happened, you wouldn’t need to do compliance training at all; you could just sign up all of your employees for law firm email updates and call it a day. The reality is that people are busy and task-focused, and they’re most likely to just keep doing things the same way they’ve always done them until told differently.
So, if you’re making it simple, it’ll feel tough.
You will have to go beyond just explaining the legal standard to understand how your business model works, how it incentivizes people, how your processes are intended to operate, and then—as a function of that, or even in spite of it—what key people actually do in their day-to-day jobs.
Because you need to understand all of that before you can answer the simple question every employee really cares about: “so what do you want me to do?”
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