The Department of Justice recently issued an updated version of its guidance for the evaluation of corporate compliance programs. This updated document is quite long and detailed. The updated compliance training requirements includes similar material to the 2017 version along with the addition of questions prosecutors might pose when analyzing training programs. It is no longer enough to simply train employees on compliance; it is also necessary to test employee understanding of compliance and determine if the compliance program is actually effective.
The Purpose of Compliance Training Programs
Compliance training programs must be designed to prevent and identify wrongdoing. This is precisely why compliance training should be performed across posterity rather than a once-off at the outset of a new hire’s employment. The moral of this story is employees should behave in a moral manner not just because it is what their employer desires; employees should behave morally as it is what they truly want to do. However, even if you have the most effective compliance training program in existence, it will not guarantee employees do not engage in misconduct. Let’s take a quick look at a few compliance training tips that will help maximize the impact of this training.
Compliance Training Should be Realistic
Provide employees with real life scenarios during compliance training. This way, the training will feel more realistic than academic. Providing realistic scenarios makes employees feel as though they are genuinely prepared for potential compliance scenarios that might arise in the future. If your compliance training materials are unrealistic, it is only a matter of time until employees tune out the message.
Whistle Blowing Should be Encouraged
All too often, employees refuse to speak up when they know something is wrong simply because they fear repercussions. Make it perfectly clear during compliance training that employees should speak up when aware of a compliance violation or other wrongdoing in the workplace. Educate every employee about the process for reporting breaches of policies, codes and laws. This way, your employees will act as a sort of internal police force that ensures co-workers follow the rules.
Be Careful When Choosing Your Compliance Training Material
Compliance training materials can be provided in a number of different forms. From online e-learning to teaching on-site, virtual reality experiences and beyond, there are a ton of different ways to provide employees with compliance training materials. Choose the format best for your unique compliance concerns and employees to make a truly indelible impact.