Written by Jon Prentice on Monday 3 July, 2023
In late May, ICA hosted a webinar looking at the importance of creating impactful compliance training. It focused on providing practical tips for engaging learners and creating impactful compliance training that goes beyond the traditional tick-box approach. Host David Povey, Associate Course Director at International Compliance Training, was joined by Paul Eccleson, Risk and Compliance Consultant at Gail Bragg, Steve Brett, Founder of E3 Compliance Training Limited, and Jochen Vankerckhoven, Founder of Compliance Explained.
Setting the scene
Host Povey started by outlining how compliance training has ‘become more important than ever in today’s rapidly evolving business landscape’, and how high quality compliance training is vital in protecting an institution from breaching rules or regulations leading to monetary sanctions. But perhaps more importantly, it can empower employees to carry out their roles to the best of their abilities, and ultimately help to protect customers. However, traditional approaches to compliance training can have minimal impact as they often leave learners uninterested, disengaged and fatigued, which is where intervention is required to ensure that the training becomes impactful.
Determining the primary reason for learner disengagement in compliance training
The opening poll of the webinar focused on the primary reasons for learner disengagement in compliance training. With the options given as: lacking interactive and engaging content, which received 29% of the votes, lengthy and dense training materials, which garnered 35% of the votes, limited relevance to job roles and responsibilities received 27% of votes and insufficient interactivity and learner participation got 9% of the votes. Eccleson opened up the discussion by considering how the current approach to compliance training in so many organisations isn’t written with the intention to change behaviours, but simply to protect the company, and so it is driven entirely around meeting regulatory requirements.
One reason for this is that measures of ‘successful’ compliance training currently constructed around the number of employees who complete the mandatory training, whereas it should be measured through behavioural changes such as the number or quality of Suspicious Activity Reports (SARs), the reduction in compliance breaches, or an increase in questions to and engagement with the compliance department.
Vankerckhoven agreed with Eccleson’s assessment, adding that the format and appearance of training is also a big reason for learner disengagement. Typically, a lot of training modules are simply PowerPoint presentations that have been added to an online system, with training just listing all the regulatory risks for learners to remember, without allowing for learner engagement, interaction or feedback. He likened it to attending a yoga class and receiving a lecture from the yoga teacher without actually doing any exercises.
Brett echoed the views of Eccleson and Vankerckhoven , before adding that historically the process most people use to produce compliance training was developed many years ago when compliance was treated as just a box ticking exercise. Whilst the compliance industry has continued to grow and evolve since then, the training provided hasn’t kept up with the pace of change, as many companies see it as being easier and cheaper to keep it the way it always has been.
The power of audience driven training
The second poll of this webinar explored the importance of audience driven training, and how it maximises learner engagement and knowledge retention. A majority of 70% of the audience agreed that it was extremely important, which opened up the discussion amongst the panel. Vankerckhoven is of the belief that the aim of the training should be to get everybody on the same page, and that the training should be made relevant to the audience’s tasks and responsibilities, ideally through scenario-based training activities.
Brett added to Vankerckhoven’s comments by highlighting how important it is to ensure that learners want to take the training, and they aren’t just completing it because the business tells them they have to. The best way to create training that is interesting to learners, and that they feel they have actually learned from it, is for those producing the training to put themselves in the shoes of the learners, gain an understanding of what motivates them, what engages them, what challenges they face, and what has the greatest impact on them.
It is here Eccleson introduces a behavioural framework known as EAST. This represents the principles that, when trying to engage people in learning, the learning should be:
Easy – this doesn’t mean the training itself has to be easy, but the materials need to be easily accessible and available.
Attractive – training material should be visibly appealing and interactive.
Social – the training should be made social, and reflective of the day to day activities the learners undertake.
Timely – Training should be as frequent as required, not just a once a year exercise.
Metrics for success
The third question posed to the audience and the panel was which data driven metrics are most valuable in assessing the effectiveness of compliance training with a vast majority of 77% of respondents saying that real life application and behaviour change was the most important metric.
Brett highlighted that completion rates were an important metric and should not be ignored, however, if this is the only metric that is being used then people are not going to get to where they need to be with regards to compliance training. Making sure people are being trained is an important first step, but to ascertain whether it is having an impact, linking to operational metrics is a must. For example, looking at ‘near misses’ regarding regulatory breaches, or root causes for breaches, and seeing whether these metrics improve over time.
Vankerckhoven added that in order to establish effective metrics, it is important to take a step back and focus on internal investigations that have taken place in your organisation, what has happened, what was done, and then measure against that in the future to establish whether training is having an impact. Simply put, find something that went wrong, find the solution, conduct training around this scenario and, over time, measure whether the initial issue has been improved upon.
Eccleson discussed a couple of dangers relating to metrics, one being ‘the attitude behaviour gap’, and another being the importance of not setting the wrong metrics.
How can compliance officers promote engagement?
The final poll of the roundtable discussion asked the audience ‘What is the most important role of a compliance officer in promoting learner engagement during compliance training?’ The poll revealed that 35% of respondents believe that delivering interactive and engaging training sessions to empower learners is the most important role, followed by 28% who believe that it is creating a supportive and open learning environment. 21% of the audience are of the belief that regularly communicating with learners and addressing their concerns is of top importance, and finally, 16% voted for providing clear and relevant training objectives and expectations as the most important.
Eccleson outlines what a difficult task compliance officers face in promoting learner engagement during training. The day-to-day roles of the compliance officer focuses on regulation, regulatory risk, writing and implementing policies, and compliance officers have to try and influence their teams, often made up of many individuals, who actually do the day to day work and are the risk takers. He is of the belief that the primary role of the compliance officer is influencing, negotiating and communicating the right set of behaviours and not the wrong ones, with training being just one facet of this.
Brett expressed that it is important that compliance officers ensure all staff members are trained to the same level, as often the weakest link in an organisation is not where you think it is. From there, extra or more specialised training can be delivered to specific teams if needs be. However, more often than not most areas of the business need to have an awareness of those risks as well. Sometimes keeping things simple and giving all staff members the same training can be a better solution.
Vankerckhoven added that it is crucial for compliance officers to always link to the original learning objectives and build from there. He also believes it is important to consider which staff members just need information, which require awareness, and which need to take actions. He further adds that the role of the compliance officer is currently very difficult as it has several remits, such as the regulatory role it plays, the role of an educator, or even an entertainer to drive engagement in compliance training, and finally the role they play with regards to environmental, social and governance (ESG).
Quick practical take aways
The session closed with the experts on the panel giving the audience some quick takeaways. You can view these takeaways in the video below.