May 19, 2009
A comprehensive approach to training far-flung employees can be daunting in terms of both time and expense. And yet, reaching these employees with a strong message and giving them a chance to ask questions relevant to their markets is critically important to a robust anti-bribery program. On-line training can be an important part of a training program, but on-line training alone cannot replace the opportunity to ask sensitive questions of compliance personnel. In-person training is ideal, but when companies have facilities in dozens of countries, it can be difficult – and prohibitively expensive – to reach everyone.
We have seen a third option used with great success. Companies can have an in-house training session filmed and, when shown, followed by a live Q&A session. The program to be filmed should be designed carefully, with opening messages from senior management and presentations from legal, compliance and audit. Any Q&A should be heavily edited. The production values should be high.
When this in-house video is shown at other offices, it should be followed by a moderated teleconference with responsible compliance staff. Whoever hosts the event is responsible for (1) explaining the purpose of the training; (2) moderating questions from the audience for the compliance officer or counsel on the phone; and (3) tracking attendance.
Planned carefully, this can be a very robust and inexpensive way to reach a large number of employees with a clear, tailored and forceful compliance message.