Ethics & Compliance Training for the Hardest Groups of All

Any compliance program worth its salt has been training senior executives for years now on the importance of embracing compliance and striking the right tone at the top.

In the real world, however, compliance officers have several more crucial employee groups to worry about, too: hourly employees, who often have tight schedules and few close bonds to the corporation overall; middle managers, whose experience with senior leaders coming and going might leave them cynical; and overseas employees, far removed from headquarters both literally and figuratively. How do you train these types effectively?

The solution probably will require a sustained effort for each group, as well as a mix of tactics. “You have to work a little harder to reach non-desk employees,” says Elizabeth Cogswell Baskin, CEO and executive creative director at Tribe Inc., an Atlanta-based internal communications agency. “There's no silver bullet.”

Start with employees paid an hourly wage. Conveying messages about ethics and compliance to salaried employees is often fairly easy, says Frank Geovanello, manager of compliance services at Altria Group. Above all, usually you can push those messages via electronic means. “They're all wired and conditioned to receive messages this way,” he says. Similarly, salaried employees routinely get together in person, such as for staff or department meetings.

Not so for hourly workers, Geovanello says. Some have no access to a computer while on the job. Many cannot easily spare an hour or two for training without finding someone to cover the operations on which they're working. And while arranging meetings after working hours may alleviate the need to find replacement help, employees may be worn out and focused more on getting home than the message being conveyed. (Managers might not be thrilled at the expense of overtime, either.)

How best to reach the hourly group? A few ideas are below. 

Plan ahead. Meetings or training sessions for hourly employees have to be “very scripted with roles and responsibilities clearly laid out,” Geovanello says. After all, some meetings likely will take place in the middle of the night for teams on the graveyard shift—not the ideal time to discover that required reading materials are missing. If training happens during working hours, line up replacement employees in advance.

Include the executive team. Even if top executives can't meet everyone on every shift, “there's something about top management reaching out,” Baskin says. Making the effort shows employees that management respects their contributions to the business. As a result, employees are more likely to be invested in the message. 

Don't overcrowd training sessions. Given the logistical challenges inherent in arranging compliance training with hourly employees, a natural impulse for compliance executives is to squeeze as much material as possible into a meeting of as many employees as possible. The risk, Geovanello says, is “not being able to connect with folks as you'd like.” Yes, you want to help employees understand the material, but you also want them to know why ethics and compliance are important. That can be harder to convey in a session of hundreds.

Engage the audience. While slides and graphics may be part of the presentation, relying on them alone probably won't do the trick. For example, Altria had some groups of workers act in skits showing, say, how to operate a new piece of equipment. The skits were filmed and shown to other employees. “When people see themselves and people they know, it excites them about the issue,” Geovanello says.

Reaching employees who work far from the home office, in different cultures and speaking various languages, presents both logistical and communication challenges. Compliance officers need to reach these employees in ways that are both practical—few companies can afford to send compliance personnel to all their locations around the globe—and relevant. The key: “Think globally, execute locally,” says Christopher Burgess, president of Prevendra, a consulting firm with expertise in security and compliance.

Use technology to reach far-flung employees affordably. Marsh & McLennan, an insurance and consulting firm that employs about 54,000 people across 100 countries, has used film. The productions are translated or used with sub-titles in more than a dozen languages, and shown at the company's locations around the world, says Scott Gilbert, chief risk and compliance officer.

“You have to work a little harder to reach non-desk employees. There's no silver bullet.”

—Elizabeth Cogswell Baskin,

CEO, Executive Creative Director,

Tribe Inc.

Help employees understand importance of work they do. For instance, the film Marsh & McLennan produced to introduce a new code of conduct shows the company's employees engaged in such activities as working with survivors of the Chilean earthquake of 2010 and helping clients obtain terrorism insurance. These scenes reinforce the importance of the company's mission, increasing employees' pride in the organization. “From that came a sense of responsibility to do our work in an ethical, responsible way,” Gilbert says.

Connect on emotional level. “We want to speak to people in a way that's compelling,” Gilbert says. That way, employees are more likely to take to heart the importance of compliance and ethics. Marsh Mac applies cinematic techniques, including music, camera angles and editing, to create an effect in its films. Using employees as actors also generates excitement and enhances realism.

Speak the local language. “If you're global and publish things only in English, you're sending the message that you're U.S.-centric,” Gilbert says. For the initial film Marsh Mac produced, the employees spoke in their native languages. Sub-titles were then included for showings in other areas.

Reaching middle managers has become increasingly important, too, given their role in furthering the company's culture of integrity and compliance. After all, “middle management is leadership's voice and face to the rank-and-file,” Burgess says.

Studies have shown that more than two-thirds of employees who bring forth a compliance concern do so through their direct manager, rather than through human resources or an ethics hotline, says Mary Beth Taylor, assistant general counsel for compliance at U.S. Steel. These managers “will be facing the issues employees bring to them, and they need to understand what their critical role is.”

Let middle managers know the resources available to them. While you want middle managers to know they have an important compliance role to play, you also want them to know that they're not in this by themselves, Taylor says. They can, for instance, talk over issues with a compliance officer or human resources representative.

Train middle managers so they can handle the situations they're likely to face more effectively. Often, an employee coming to a middle manager may be nervous and uncomfortable trying to articulate the issue he or she is facing, as well as unsure whether it even presents a compliance dilemma. The middle manager needs to elicit information in a way that doesn't frighten the employee, and then identify the issue at stake, as well as the possible options, Taylor notes. Say an employee tells a manager that his or her spouse works for a vendor with which the employee interacts. Is this a conflict? If so, can it be handled?

Where possible, replace “no” with “how.” That is, Baskin says, employees may come forward with ideas that go against the spirit of compliance. Before dismissing them outright, managers (often with help from compliance) can try to work with the employee to determine how they can accomplish the business goal in a way that is ethical.

Lastly, let middle managers know they need to model the behavior they expect their employees to follow. “Their employees don't see the people in the executive suite. They see their managers every day,” Taylor says.