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Best Practices In Compliance Training

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Contributor, Ekomobong E. Ekpro is a lawyer currently working in-house in a multinational energy trading company. She is passionate about writing on compliance issues, particularly on compliance culture, anti-bribery, and training. She received her LLB and LLM from the University of Sussex, Brighton, UK. She is called to the Nigerian Bar Association and is an Associate Member of the Institute of Chartered Secretaries and Administrators of Nigeria. Ekomobong started her legal career in a boutique law firm that specializes in criminal and civil litigation and transitioned in-house where she currently works in the legal department of a multinational energy trading company to ensure the legal function is effective in meeting the corporate needs of the organization. She currently supports the compliance function in its operationalization of the anti-corruption program and enjoys the creative aspects of it. Currently, Ekomobong devotes her time to learning about anti-bribery compliance, networking with compliance professionals, and writing on compliance issues of interest. You can find Ekomobong on LinkedIn.

best-practices-in-compliance-training.jpg Training and communication are ethics and compliance components that I think about often. I think about what makes training engaging, and how to communicate my training program in a way that is persuasive and can influence behavior. Subject matter experts agree that training is one of the cornerstones of any ethics and compliance program's objective to promote an ethical culture, communicate leadership's message on the company's commitments to ethical values, laws, standards, policies, and procedures, and mitigate risk.

I believe the importance of training in any ethics and compliance program cannot be overstated, chiefly because regulators demand that training and communications form an integral part of any ethics and compliance program. In addition, training creates the added value of keeping ethics and compliance issues top of mind in employees. This is especially true if communication is done well and in an ongoing fashion that reinforces the ethical and compliance messaging a company's governing authority seeks to convey. This will, in turn, mitigate risk and keep the company away from reputational and legal trouble.

Further, because regulators understand that an effective training program is an essential component of any ethics and compliance program, they have laid out guidance in several guidance documents that describe training practices companies can adopt. In my opinion, the France Agence Francaise Anticorruption (Hereafter AFA) guidance document does a wonderful job of outlining practical ethics and compliance training best practices and is rooted in learning theories that, if adopted, can facilitate training effectiveness. I will highlight the training guidance notes from the U.S. Department of Justice and France AFA.

The US DOJ, in evaluating the adequacy and effectiveness of any company's ethics and compliance program, lays out in its Evaluation of Corporate Compliance Programs guidance document various topics prosecutors will consider in deciding the effectiveness of any program. One of them is 'Training and Communication'. The DOJ gives some pointers as to compliance best practices - in stating that a hallmark of a well-designed compliance program is appropriately tailored training and communications.

In assessing a company's compliance program, the DOJ will consider the steps taken by the company to embed its policies and procedures into its operations. In particular, the DOJ will consider the following:

  • The frequency of training including certifications for all directors, officers, relevant employees, and where appropriate, agents and business partners.

  • Whether the company communicates training in a risk-based approach including the extent to which a company has measured the impact of training on employee behavior or operations.

The DOJ also requires that the company explain its rationale for its choice of form and content of the training program. They also expect to see prior compliance incidents form part of the training program and whether employees are tested on their knowledge.

The AFA's guidance joins others to advocate for a risk-based approach to training programs, in other words, training for those employees with the greatest exposure to ethics and compliance risks. The purpose of this is to promote vigilance, inform high-risk employees of the due diligence obligations required for their role, the behavior to adopt in high-risk scenarios, and assume ownership of the company's compliance program.

What I find interesting about the AFA's guidance, is that it recommends best practices in compliance and ethics training and is rooted in a potpourri of adult learning theories that include self-directed, experiential, and transformational learning.