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DON’T GOHALFWAY.GO 360.COMPLIANCE PROGRAM EFFECTIVENESS: You’ve established a complianceprogram – but can you prove that it’s working? Regulators now look beyond the presence of a compliance program,demanding concrete evidence that that your program is effective. Partial compliance is non-compliance. You need acomprehensive, unified solution that helps you identify and fix the gaps… before something falls through them.Learn more at the Compliance Effectiveness Resource Center: visit www.compliance360.com/EffectiveCompliance.GET THE 360° VIEW.www.compliance360.com
y Charles RuthfordIs your ethics and compliancetraining really preparingyour employees?»»Our current web-based ethics and compliance training may leave us unprepared for people having to deal with risks.»»We cannot assume that people under stress will first consider a rational, step-by-step process to deal with a risk.»»When facing a difficult situation that has personal consequences, the human mind bases its choices on intuition andemotion rather than rational reasoning.»»Interactive, collaborative, transformative, management-led learning activities can influence values, intuition, behaviors,decision-making, and ultimately bottom-line performance.»»Leadership and involvement by front-line managers is crucial to the success of training and change activities.RuthfordIhave good news and bad news. First letme give you the good news: Over the pastfew decades, the technology for onlineweb-based training has evolved significantly.Today’s courses are readily available, scalable,efficient, and reasonably good at conveyinginformation.The bad news? Online trainingdoesn’t typically prepare people toreact properly when faced with anethics challenge or compliance risk.In this article, I will show why onlinetraining comes up short. I also willdescribe how interactive, collaborative,transformative, management-led learningactivities can prepare people for thosedifficult situations.HistoryWhen we developed ethics and compliancetraining in the early 1980s, we used a fairlysimple approach. We explained the rules andexpectations, and made the consequences formisconduct clear. We provided the learnerwith tools such as an ethical decision-makingmodel that, if applied correctly, wouldlead people to the proper decision. And wedirected them to their management or anethics hotline for advice and help.These courses were designed and built byskilled training developers. They used stateof-the-artprocesses and were delivered byexperienced trainers. We started in the classroomand, over the years, transitioned to thepresent-day web-based delivery. The premisefor our design approach was simple: Becausepeople want to avoid the pain that couldresult from a misstep, they would recognizethe issue, pause before acting, and then gothrough an objective, step-by-step decisionmakingprocess. They then would respondappropriately to the questionable situation,and the sun would rise over our untarnishedreputation yet another day.Making choicesOur previous assumptions about how peoplereact under stress—and how this affects theirethical decision-making—may not be correct.Nobel Laureate Professor Daniel Kahnemanshows that people facing difficult situationsreact quickly. Their split-second choicesCompliance & Ethics Professional March/April 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 63
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