Compliance &Ethics - Society of Corporate Compliance and Ethics

The Art of Complianceby Art Weiss, JD, CCEP, CCEP-IDon’t train your employees —your hotline calls will increase!WeissDon’t you hate it when the “businesstypes”’ (you know, those folks whothink we’re out to get them) complainthat the number of hotline calls is rising? Thisusually happens right after you complete around of training, particularly topics such asgifts, conflicts of interest, and preventionof harassment. These folks mustthink they will look bad if more ofthe employees in their departmentsreport illegal or unethical conduct.Obviously, if more hotline reports arecoming in, the place is going downthe drain, right? Wrong!Why do we do training in the firstplace? Is it because we like spending bucketsof money with outside vendors to put our logoonto their cut-and-paste videos? Is it becausewe like putting on the same class four timesa day with the first session at 5 a.m. and thelast at 8 p.m.? Maybe it’s because we like toshow off how smart we are and try to makethe employees think that we know all theanswers. Again—wrong, wrong, and wrong!Nope, we train because we want ouremployees to work safely, treat each otherrespectfully, build our corporate reputation,and oh yeah, stay out of jail. Some trainingis required by law; some is “required” by theFederal Sentencing Guidelines or similar internationalguidance. I’d like to think that wetrain so that our employees and our organizationcan prevent and detect violations of lawand foster an ethical culture. Now, where haveI heard those words before?In the SCCE Basic Compliance and EthicsAcademy, we have a class on training andeducation. As part of that class, attendees areasked to break into small groups and preparea presentation to their ”CEO” (an instructor)justifying their compliance training budget.It’s a very popular break-out session. Thethings they come up with to justify theirbudget range from “doing the right thing” tokeeping the CEO out of jail.…we train because we wantour employees to work safely,treat each other respectfully,build our corporate reputation,and oh yeah, stay out of jail.Take some time to think about why yourorganization conducts compliance training.Think about how you can improve your training,and think about how you can justify yourneed for training. After all, you are teachingyour employees to identify illegal andimproper conduct so they can drive the “businesstypes” crazy with more hotline calls. ✵Art Weiss (art_weiss @ tamko.com) is Chief Compliance and Ethics Officerat TAMKO Building Products in Joplin, MO.Compliance & Ethics Professional May/June 2013+1 952 933 4977 or 888 277 4977 www.corporatecompliance.org 31