2014 Ethics & Compliance Training Benchmark Report

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Data and Analysis to Enhance Your Training Program’s Effectiveness

NAVEX Global’s 2014 Ethics and Compliance

Training Benchmark Report

July 2014

PREPARED BY:

Mary Bennett, R.Ph. Vice President,Advisory Services, NAVEX Global

Ingrid Fredeen, J.D, Vice President,Advisory Services, NAVEX Global

© 2014 NAVEX GLOBAL, INC. ALL RIGHTS RESERVED. 2014 NAVEX Global Ethics and Compliance Hotline Benchmark Report 2

TABLE OF CONTENTS

I. Introduction

II. Survey Respondent Profile

III. Executive Summary

IV. Key Findings

A. The State of Ethics & Compliance Training Today

1. Ethics & Compliance Training Objectives

2. Training Challenges & Barriers

3. Overall Program Outlook

4. Program Gaps Persist

• Supervisor Training

• Non-Supervisory Employee Training

B. Benchmarking Ethics & Compliance Training

1. Training Hours

• Number of Hours Per Employee Role

• Number of Courses Offered Annually Per Employee Role

2. Training Topics

3. Training Formats

C. The Future of Ethics & Compliance Training

1. Overall Training Trends

2. Focusing on Quality and Effectiveness

3. Doing More With Less

4. Measuring Effectiveness

V. Conclusion & Key Takeaways

VI. About the Authors & NAVEX Global

© 2014 NAVEX GLOBAL, INC. ALL RIGHTS RESERVED. NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report 3

I. INTRODUCTION

In early 2014, NAVEX Global partnered with an independent research agency to survey ethics and compliance professionals with responsibility for administering training across their organizations. The purpose of the survey was to provide the industry with data on an overlooked area of research: benchmarking the top priorities and challenges in disseminating ethics and compliance-focused training.

The findings discussed represent responses from more than 750 key decision-makers and individuals responsible for ethics and compliance programs. (See respondent profile in the next section for additional details.)

This report provides the most compelling results, providing insights on such questions as:

− How much ethics and compliance-focused training are organizations doing?

− What training methods are being used?

− Are compliance professionals satisfied with their training programs?

− How is program effectiveness being measured?

− How will training programs evolve in the future?

How To Use This ReportTraining accounts for the largest percentage of ethics and compliance program budgets1, and is one of the key elements of an ethics and compliance program. Learning what your peers are doing is essential in helping you evaluate your program in a broader context. It may also reveal areas where your program may need to grow or evolve.

We hope you will find this data useful—and that it will provide both inspiration and motivation to make your ethics and compliance training program even more effective.

1. NAVEX Global Research, 2014 Key Trends for Ethics and Compliance Planning

©2014 NAVEX GLOBAL ALL RIGHTS RESERVED. 2014 NAVEX Global Ethics and Compliance Hotline Benchmark Report 4

2

1

4

3

6

5

8

7

10

9

Healthcare Providers

Energy & Utilities

Government

Banking & Financial Services

Manufacturing

Insurance

Non Profit

Higher Education

Healthcare Products

Retail & Leisure

Decision-Maker

Non-Decision Maker

No Compliance Training Responsibilities

Other

Ethics & Compliance

Human Resources/Employee Relations

Training/Learning and Development

Legal

Small: <500 Employees

Medium: 500-5000 Employees

Large: 5000+ Employees

Training Decision Maker Status

Job Function

Company Size

Geography of Headquarters

Other

C-Level

Senior Management

Non-Management

Management

Job Function

Other

Top 10 Industries

CANADA

USA88%

EMEA7%

APAC3%

LATAM1%

1%

SURVEY RESPONDENT PROFILE

35%52%

5%8%

42%29%

12%

10%7%

6%

5%

48%22%

19%

37%32%

31% 39INDUSTRIESREPRESENTED

=763


III. EXECUTIVE SUMMARY

Benchmarking your training program is key to understanding your program’s performance, and making improvements. The NAVEX Global 2014 Training Benchmark Survey reveals important trends and insights that will help you critically evaluate your own training program today and make key decisions that will shape the future of your program. Because training programs are a critical part of an effective compliance program, they will continue to be exposed to increased pressure to demonstrate strong results.

Survey data revealed the top objectives, pain points and training program strategies for ethics & compliance professionals across many industries. The following key themes emerged:

− Culture Prevailing Over Defensibility as Main Objective: Respondents identified their top objective as “creating a culture of ethics and respect.” This is an important program evolution that signals a broader awareness of the need to help employees understand what it means to act ethically and with integrity—and a realization that desired compliance behaviors often flow from a culture of ethics and integrity. But creating a culture of ethics and respect tends to require greater investment of time and resources than “complying with laws and regulations”—the second most-cited objective.

− Time, Money and Measurement are the Top Challenges: While respondents noted many different program challenges, those that emerged as the most significant were available seat time, budget, and measuring program effectiveness. To meet these challenges, organizations will need to adopt new training approaches and establish performance metrics.

− Significant Concerns and Program Gaps Remain: Most respondents reported, overall, that their employees are getting the training they need. However, when asked more specifically about particular audience groups, respondents revealed significant concerns about the effectiveness of their training efforts.

− Diversification of Training Formats: Respondents are using a wide variety of training formats to reach and engage their key audiences, with six being the average number of formats used in a single curriculum.

− Quality is Key to Training Effectiveness: Respondents believe that high quality training is essential for training that truly engages. As organizations strive to build ethical cultures and change employee behaviors, a focus on quality will become increasingly important. Quality is key to effectiveness, with some instructional formats and approaches receiving higher marks in effectiveness than others.

− The Rise of Short-Form Training: Covering more risk areas with limited training hours and pressured budgets is a significant priority for survey respondents. A growing number are working to accomplish this through short-form training.

In general, for most respondents, “good enough” is no longer enough when it comes to the most significant spend of an ethics & compliance budget. As training program goals move beyond compliance and towards focusing on a culture of ethics and respect, more pressure will be placed on using training to drive behavioral change, not only to help build legal defenses.

With more ambitious training objectives and a rapidly-evolving industry landscape, compliance professionals need to ensure that their programs are keeping pace with the rate of change. By taking a fresh approach and building training programs that are mapped to risks and audiences, training can become a much more effective tool in protecting an organization’s people, reputation and bottom line.

THE STATE OF ETHICS & COMPLIANCE TRAINING TODAY

IV. KEY FINDINGSThe State of Ethics & Compliance Training Today


1) Ethics & Compliance Training ObjectivesFINDINGS: Ninety percent of survey respondents cited their top ethics and compliance training objective as “Create a culture of ethics and respect.” This is closely followed by “complying with laws and regulations” (89 percent) and “preventing future issues or misconduct” (82 percent).

Top Ethics and Compliance Training Objectives

ANALYSIS: Once focused almost exclusively on establishing important legal defenses, the new top priority for compliance training is building an ethical culture. This trend is true even among ethics and compliance and legal job titles that have traditionally been more focused on program defensibility.

Increasing Awareness of Training’s Impact on Corporate Culture

This is an important change within the field, pointing to an increasing awareness of the impact of strong compliance training curricula on building and sustaining an ethical corporate culture.

However, it also points to a major challenge for ethics and compliance professionals. “Check-the-box” training will not help organizations achieve the culture and behavior change goals they are clearly chasing. In fact, outmoded training can backfire by increasing employee cynicism. Bland training programs that are neither relevant nor engaging will not close the gap. High-quality, engaging training must become the norm (not the exception) and must be combined with other elements of a holistic and robust compliance program designed to pursue these important goals.

0 20 40 60 80 100

90%

89%

82%

37%

45%

54%

37%

30%

18%

3%

Top Ethics and Compliance Training Objectives

Create A Culture Of Ethics & Respect

Comply With Laws & Regulations

Prevent Future Issues Or Misconduct

Meet Audit Or Certification Requirements

Address Existing Issues Or Misconduct

Improve The Organization’s Reputation

Reduce Litigation

Establish Strong Legal Defenses

Respond To Penalties Or Sanctions

Other

94% of decision-makers rate their commitment to creating a as their most important ob ject ive for t ra in ingCulture of Ethics and Respect



2) Training Challenges & BarriersFINDINGS: Over half of respondents (56 percent) cite seat time constraints as a major challenge to ethics and compliance training. A close second are difficulties measuring the effectiveness of programs (54 percent).

Top Ethics and Compliance Training Concerns and Challenges

ANALYSIS: Dealing with the constraints of time, money and measurement are perpetual difficulties for ethics and compliance professionals. The pressure to increase effectiveness despite these challenges has increased as programs have moved into second and third generation phases, and regulators have become savvier at detecting check-the-box programs.

Better Measurement, New Strategies Will Help Alleviate Top Concerns

As compliance professionals’ ability to measure program effectiveness improves, decision-makers will be better able to determine if their investments are working—and where additional resources are needed to meet goals. One strategy organizations are increasingly exploring to help overcome time and money obstacles is to employ short-from or “burst learning” training, which allows them to cover additional topics in less time, and at a lower cost, as well as refresh training more frequently.

0 20 40 60 80 100

56%

Top Ethics and Compliance Training Concerns and Challenges

10%35%

54% 6%42%

42% 14%44%

41% 13%46%

31% 15%54%

23% 10%67%

23% 18%59%

19% 24%57%

18% 36%46%

17% 22%62%

16% 57%27%

Significant Challenge Moderate Challenge Not A Challenge

Limited Hours Available For Training

Measuring Effectiveness

Not Enough Budget

Difficulty Covering All Of The Topics Important To Our Organization

Training Content Is Growing Old/Stale

Training Not Effective At Changing Attitudes Or Behavior

Training Content Is Low Quality/Unengaging

Training Content Is Not Relevant To Our Audience

Difficulty Tracking And Reporting Training Completion

Employees Respond Negatively To Training

Limited Applicability Of Training Content Outside The United States

Note: Numbers may not add to 100 percent due to rounding.



3) Overall Program OutlookFINDINGS: When asked about their outlook for their organization’s training program, 75 percent of respondents either “agreed” or “strongly agreed” that “each employee receives the ethics and compliance training they need to safeguard our people, reputation and bottom line.”

Ethics & Compliance Training Program OutlookEach employee in our organization receives the ethics and compliance training they need to safeguard our people, reputation and bottom line.

ANALYSIS: The overwhelming majority of respondents appear to believe that their programs are on the right track. However, additional data collected in our survey (see next section) suggests a startling disconnect between how training professionals feel about their programs in general, and concerns about training adequacy for specific audiences.

A Critical Eye and Commitment to Continuous Improvement are Crucial for Achieving Program Effectiveness

The existence of this gap suggests that organizations should not find comfort in their overall impression of their program. Instead, they must be more critical of individual program elements and be willing to challenge their own organizational norms when it comes to training.

They must also be willing to continuously improve programs. For organizations that have internally developed training or have not changed training formats for many years, an outside advisor should periodically review training programs. Organizations should also pay close attention to the areas of moderate concern, which predominantly relate to poor quality courses and ineffective methods. Unless these concerns are addressed, efforts to achieve important training goals will be ineffective.

Each employee in our organization receives the training they need to safeguard our people, reputation and bottom line.

Agree

Neutral

Disagree

0 10 20 30 40 50 60 70 80

75%

12%

13%

Ethics and Compliance Training Program Outlook

Strongly Agree Somewhat Agree

StronglyDisagree

SomewhatDisagree



4) Program Gaps PersistFINDINGS: When asked to provide details about the effectiveness of training specific audiences, respondents revealed some startling concerns that contradict their otherwise positive attitudes about the effectiveness of their training programs overall. Fifty-four percent of respondents say they are concerned that their supervisors are not receiving adequate training, and nearly 30 percent of respondents have the same concerns related to the amount of training they are providing to non-supervisory employees. When we drill down into the concerns of specific stakeholders, we find additional insight.

Supervisor Training Respondents said that, despite the training program in place, it is either a “major” or “significant” concern that supervisors are at risk of:

− Not receiving adequate training so they understand how to avoid missteps (54 percent)

− Mishandling or downplaying complaints or reports from employees (46 percent)

− Demonstrating attitudes or conduct not reflective of our commitment to ethics and compliance (38 percent)

Areas of moderate concern represent significant warning signs that only reinforce the importance of focusing on managers in the next several training cycles.

Top Ethics and Compliance Conduct Risks for Supervisors Respondents were asked to rate their level of concern about the following risks facing the supervisors in their organizations:

Not receiving adequate training to help avoid missteps Mishandling or downplaying complaints or reports from employees

Exhibiting attitudes or conduct that undermines our commitment to ethics and compliance

Exerting or giving in to pressure to compromise standards to achieve business results

Retaliation (mistreating or taking action against an employee after a report is made)

Ethics and compliance is not strongly backed by senior leaders

Discriminatory hiring, �ring or performance management decisions

0 20 40 60 80 100

Significant Concern Moderate Concern Not A Concern

46%

54%

38%

35%

33%

27%

27%

41%

41%

50%

50%

48%

40%

52%

13%

6%

12%

16%

19%

32%

20%

Not Receiving Adequate Training To Help Avoid Missteps

Mishandling Or Downplaying Complaints Or Reports From Employees

Exhibiting Attitudes Or Conduct That Undermine Our Commitment To Ethics And Compliance

Exerting Or Giving In To Pressure To Compromise Standards To Achieve Business Results

Retaliation (Mistreating Or Taking Action Against An Employee After A Report Is Made)

Ethics And Compliance Not Strongly Backed By Senior Leaders

Discriminatory Hiring, Firing Or Performance Management Decisions




4) Program Gaps Persist (continued)

Non-Supervisory Employee Training Sixty-two percent of respondents are satisfied with the training they provide to non-supervisory employees—regardless of whether they deliver a lot of training or very little. However, 29 percent of respondents are concerned about the amount of training they provide to non-supervisory employees.

Non-Supervisory Employee Training Levels

ANALYSIS: Supervisors and managers are the daily interface with the employees who form the foundation of an organization. In today’s highly complex and heavily regulated business environment, arming managers with the skills they need to navigate the ethics and compliance challenges they will inevitably face is critical. As the numbers reveal, there is significant concern about whether managers are equipped to properly support the culture—and whether they will inappropriately downplay complaints. Organizations must quickly identify manager training gaps and focus on addressing them in the coming training cycle.

Organizations must also evaluate the training they are providing to non-supervisory employees. Employees on the frontlines are often the first to see many forms of misconduct. It is crucial that they understand the behavior that aligns with the organization’s standards, can recognize misconduct and know how to report violations.

Educated Employees are the Foundation of a Strong Ethics and Compliance Program

Poorly and inadequately trained employees will undermine an organization’s attempts to achieve the most important goals of the training program: creating a culture of ethics and respect and complying with laws and regulations.

By evaluating the content of their training, ensuring that the messaging is appropriate, and making choices that maximize budget and protect precious seat time, organizations can more effectively reach all employees without negatively impacting budgets or available training time.

12%

50%

25%

2%

11%

Other

We Provide Very Little Training To Employees

Adequate Training Provided Inadequate Training Provided

We Offer Very Little Training To Employees

We ProvideSignificant Trainingto Employees

We Can’t Afford To Provide Training To Non-Supervisory Employees

BENCHMARKING ETHICS & COMPLIANCE TRAINING


IV. KEY FINDINGSBenchmarking Ethics & Compliance Training

1) Training Hours

Number of Hours Per Employee Role FINDINGS: On average, organizations provide employee groups six hours of compliance training annually, and 76 percent of organizations are deploying five or fewer hours of training annually. Board members and third parties receive even less training than employees.

However, a look at median values reveals that most organizations offer even fewer training hours than the averages suggest. The median organization deploys just two to three hours of training to employee groups annually, with board members receiving one hour and third parties receiving no training.

Hours of Training Delivered Annually: Employee Groups

0 10 20 30 40 50 60 70

Hours of Training Delivered Annually

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours

Senior Leaders (n=525) Middle Managers (n=530)

0 10 20 30 40 50 60 70

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours

Employee Groups

0 10 20 30 40 50 60 70

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours

Non-Managers (n=532)

8%68%

13%

7%4%

5%68%

14%9%

4%

7%

69%

12%7%

5%

1 12

middle 80% range = 1 - 12 Hours

5.83Average

1 15


6.32Average

1 15


5.98Average

2.0Median

3.0Median

3.0Median

0 10 20 30 40 50 60 70


O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours


0 10 20 30 40 50 60 70

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours

Employee Groups

0 10 20 30 40 50 60 70

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours


8%68%

13%

7%4%

5%68%

14%9%

4%

7%

69%

12%7%

5%

1 12


5.83Average

1 15


6.32Average

1 15


5.98Average

2.0Median

3.0Median

3.0Median

0 10 20 30 40 50 60 70


O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours


0 10 20 30 40 50 60 70

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours

Employee Groups

0 10 20 30 40 50 60 70

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours


8%68%

13%

7%4%

5%68%

14%9%

4%

7%

69%

12%7%

5%

1 12


5.83Average

1 15


6.32Average

1 15


5.98Average

2.0Median

3.0Median

3.0Median

On average, smallorganizations deliver

three morehours of trainingannually than large organizations to each employee group.



1) Training Hours (continued)

Hours of Training Delivered Annually: Non-Employee Groups


Non-Employee Groups

0 10 20 30 40 50 60 70

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours

Board of Directors (n=457) Third Parties (n=415)

0 10 20 30 40 50 60 70

O Hours

1 - 5 Hours

6 - 10 Hours

11 - 25 Hours

25 Plus Hours

30% 57%59%

6%3%2%

36%4%

1%

2%

3.04Average

0 6

middle 80% range = 0 - 6 hours

2.07Average

0 4

middle 80% range = 0 - 4 hours

0.0Median

1.0Median




Number of Courses Offered Annually Per Employee RoleFINDINGS: The majority of respondents’ organizations are training on one-to-five topics with approximately 96 percent of respondent organizations offering fewer than ten courses per year.

Training Courses Offered Annually: Employee Groups

0 20 40 60 80

Training Courses Offered Annually

O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses


0 20 40 60 80

O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses

Employee Groups

0 20 40 60 80

O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses


9%76%

12%

2%2%

6%76%

15%3%

1%

8%76%

12%3%

1%

1 7

2.0Median

middle 80% range = 1 - 7 courses

3.35Average

1 8

3.0Median


3.63Average

1 6

2.0Median


3.27Average

0 20 40 60 80


O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses


0 20 40 60 80

O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses

Employee Groups

0 20 40 60 80

O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses


9%76%

12%

2%2%

6%76%

15%3%

1%

8%76%

12%3%

1%

1 7

2.0Median


3.35Average

1 8

3.0Median


3.63Average

1 6

2.0Median


3.27Average

0 20 40 60 80


O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses


0 20 40 60 80

O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses

Employee Groups

0 20 40 60 80

O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses


9%76%

12%

2%2%

6%76%

15%3%

1%

8%76%

12%3%

1%

1 7

2.0Median


3.35Average

1 8

3.0Median


3.63Average

1 6

2.0Median


3.27Average




Training Courses Offered Annually: Non-Employee Groups

ANALYSIS: Organizations are deploying very few courses on an annual basis. Organizations are less focused on access to large libraries of outdated courses, and more focused on taking a risk-based approach to training.

Need for Curriculum Mapping Increasing

Curriculum mapping1 will become increasingly important to help organizations plan their programs, ensure a proper rotation of training content to all learners over a multi-year period, and enable them to more effectively allocate their training funds.

Board Members and Third Parties Remain Underserved

Two audiences that are underserved by training, despite the significant role they play and risk they can create, are board members and third parties. It is crucial for the board of directors to understand their role in compliance program oversight and in setting “tone at the top.” Equally important is an organization’s entire ecosystem of partners and suppliers and their role in contributing to a culture of compliance. Training of third parties helps prevent third-party misconduct, and helps establish key defenses when violations occur.

0 20 40 60 80


O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

16 or More Courses

Board of Directors (n=455) Third Parties (n=405)

0 20 40 60 80

O Courses

1 - 5 Courses

6 - 10 Courses

11 - 15 Courses

25 or More Courses

Non-Employee Groups

33% 55%61%

5%1%0%

41%3%

1%

0%

1.15Average

0 3

0.0Median


1.77Average

0 4


1.0Median

1. Curriculum Mapping is the process of aligning training with audience roles and organizational risks.



2) Training Topics FINDINGS: Overall, “Ethics and Code of Conduct” training was the clear frontrunner for training topics, with “Workplace Harassment” a close second and “Conflicts of Interest” a distant third.

When broken out by job role, ethics, compliance and legal professionals prioritize “Ethics and Code of Conduct,” “Conflicts of Interest” and “Gifts and Gratuities” training, while HR and learning and development professionals place a greater emphasis on “Workplace Harassment,” “Discrimination” and “Diversity & Inclusion” training (See next page).

Training Topic Priorities for the Next Two to Three Years

0 10 20 30 40 50 60 70 80 90

Training Topic Priorities for the Next Two to Three Years

79%68%

66%60%

58%

56%48%

41%41%

37%

37%35%

29%27%

26%22%

16%

85%

13%19%

Ethics & Code Of Conduct

Workplace Harassment

Conflicts Of Interest

Confidential Information

Discrimination

Gifts & Gratuities

Reporting & Retaliation

Data Privacy

Social Media

Bribery & Corruption

HIPAA

Diversity & Inclusion

Cyber Security

Antitrust & Competition Law

Wage & Hour Laws

Third Party Compliance

Insider Trading

Trade Sanctions & Compliance

Money Laundering

Other



2) Training Topics (continued)

Priorities for the Next Two to Three Years: By Job Function

0 25 50 75 100

Ethics, Compliance, and Legal (n=289)HR, Learning and Development or Training (n=197)

0 25 50 75 100

90%79%

72%

70%70%

60%60%

52%51%

44%

38%37%37%

37%31%

29%21%

20%19%

15%

91%78%

74%63%

57%55%

44%43%

38%38%

38%34%

29%

25%18%

17%14%

12%9%

7%

Workplace Harassment *Ethics & Code of Conduct *

Discrimination *Confidential Information

Conflict of Interest *Reporting & Retaliation

Diversity & Inclusion *Gifts & Gratuities *

Social Media HIPAA

Wage & Hour Laws *Data Privacy *

Cyber Security *Bribery & Corruption *

OtherThird Party Compliance *

Antitrust & Competition Law *Insider Trading *

Trade Sanctions & Compliance *Money Laundering*

0 25 50 75 100


0 25 50 75 100

90%79%

72%

70%70%

60%60%

52%51%

44%

38%37%37%

37%31%

29%21%

20%19%

15%

91%78%

74%63%

57%55%

44%43%

38%38%

38%34%

29%

25%18%

17%14%

12%9%

7%

0 25 50 75 100


0 25 50 75 100

90%79%

72%

70%70%

60%60%

52%51%

44%

38%37%37%

37%31%

29%21%

20%19%

15%

91%78%

74%63%

57%55%

44%43%

38%38%

38%34%

29%

25%18%

17%14%

12%9%

7%

Ethics & Code of Conduct *Conflict of Interest *

Workplace Harassment *Gifts & Gratuities *

Confidential Information Data Privacy *

Reporting & Retaliation Bribery & Corruption *

Discrimination *Social Media

Cyber Security *Antitrust & Competition Law *

Third Party Compliance *HIPAA

Diversity & Inclusion *Insider Trading *

Trade Sanctions & Compliance *Other

Wage & Hour Laws *Money Laundering*

0 25 50 75 100


0 25 50 75 100

90%79%

72%

70%70%

60%60%

52%51%

44%

38%37%37%

37%31%

29%21%

20%19%

15%

91%78%

74%63%

57%55%

44%43%

38%38%

38%34%

29%

25%18%

17%14%

12%9%

7%

* Indicates significant difference among groups



2) Training Topics (continued)ANALYSIS: Because an organization’s code of conduct continues to act as a foundational compliance element, it is no surprise that it is the most frequently trained topic, with harassment a very close second. These two cornerstone courses are deployed to the widest audiences and should be a representation of an organization’s commitment to compliance, integrity and respect. Investing appropriately in these titles will help create a strong foundation for an effective training program.

Aligning Training Topics to Risk Profiles and Legal Requirements

To maximize program effectiveness within finite budgets and competing priorities, it is best to align training topics with an organization’s risk profile and legal requirements. This will help ensure that training as a control is in place to address the highest risks and that all legal training mandates are met.

Increased Focus Needed on Communication and Privacy-Related Conduct

That said, several areas that pose significant legal and reputational risk for most organizations ranked surprisingly low. Regulatory and enforcement pressure has made privacy and technology security paramount concerns for today’s businesses. But despite this focus, only 48 percent of organizations plan to provide data privacy training, and only 35 percent plan to provide cyber security training.

Likewise, despite the benefits of providing employees with social media training, only 41 percent plan to provide such training in the next two to three years. When evaluating organizational risk and building a training plan it is important to take into consideration regulatory and enforcement trends, as well as trends in how employees communicate.



3) Training Formats FINDINGS: Online training is the most frequently-used form of training for survey respondents, with live training a close second. E-mail—whether it is used to deliver links to training, training files, or training and awareness messages and reminders—is the third most frequently-used communication format.

Beyond the top three, organizations are using a wide variety of formats, from posters and wallet cards to newsletters and webinars.

Communication Formats Used in Ethics and Compliance Training & Awareness

Communication Formats Used in Ethics and Compliance Training and Awareness

71%

68%

57%

48%

47%

45%

45%

36%

33%

31%

29%

26%

15%

11%

7%

6%

2%

0 25 50 75

Online Training

Live Training

Email

Policy Distribution or Certification Systems

Print Resources: Handbooks/Brochures/ Documents/Memos

Intranet

Posters

Informal Meetings

Newsletters

Webinars

Manager Discussion Materials

Short Training Vignettes

Wallet Cards

Digital Resources: E-Books/Microsites or Digital Guides

Social Media

Direct Mail

Other



3) Training Formats (continued)ANALYSIS: On average, respondents used six different communication formats for training and awareness. Utilizing a wide variety of formats to reach learners is most effective especially if the selected formats are designed to advance key program goals and deployed per a well thought out plan.

Live Training and Blended Learning Trends

Live training was once the training staple. While it still plays a central role in the overall training program mix, survey responses indicate that online training has surpassed live training as the most-frequently-used training format. For many organizations, blended learning (using both live and online training) has emerged as an effective way to train the highest-risk employees. For instance, organizations often provide high-level bribery and corruption training to all learners online, and provide additional live training to those who deal with government officials.

Social Media Slow to Enter the Ethics & Compliance Mix

Despite the prevalence of social media in the lives of all employees, and the influence it has over how we learn and communicate, only seven percent of organizations are currently using social media as a training tool. Innovative ethics and compliance programs have started to embrace social media as a training mechanism, harnessing its power and simplicity as a low cost communication tool. By utilizing private chat functionality and communication tools, organizations are able to generate discussion and provide an opportunity for employees to interact in new and meaningful ways.

Policy Management Systems On the Rise

Technology has influenced more than just traditional training methods; nearly half of the respondents are using a policy management system to support training and awareness efforts. Policy management software systems help organizations distribute policies, procedures and regulatory requirements and collect employee attestation records. Compliance professionals are moving away from manual, paper-based distribution approaches, and toward automated, measurable systems that better support program effectiveness and efficiency.

THE FUTURE OF ETHICS & COMPLIANCE TRAINING


IV. KEY FINDINGSThe Future of Ethics & Compliance Training

1) Overall Training TrendsFINDINGS: The number one trend ethics and compliance professionals are currently applying—or will be looking to apply in the next year—is “adding course titles to cover more risk areas.” The second is improving measurement of training effectiveness, and the third is bolstering middle manager training.

Ethics & Compliance Training TrendsWhat training trends are you currently applying, or do you plan to apply in the next year?

0 25 50 75

Ethics and Compliance Training Trends54%

46%

45%

32%

35%

44%

30%

25%

21%

6%

16%

11%

5%

What training trends are you currently applying, or do you plan to apply in the next year?

Adding Course Titles (To Cover More Risk Areas)

Measuring Training Effectiveness

Additional Emphasis On Middle Manager Training

Using Shorter Courses Or Short Learning Vignettes (3-7 Minutes)

Training Executives And Board Members

Collaborative Learning (Peer-To-Peer, Or Group Discussion And Problem-Solving)

Leveraging Modular Content

Deploying Training On Mobile Devices

Training Third Parties

Curriculum Mapping

Gamification

Reducing The Number Of Course Titles

Other



1) Overall Training Trends (continued) ANALYSIS: More than half of respondents plan to increase the number of risk areas covered by their training programs. This should not be surprising, considering the relatively small number of courses currently being deployed by the vast majority of programs. However, given the constraints of seat time and budget, adding courses will mean getting creative with both the methods they utilize and the length of the training they provide.

One way that organizations can cover additional topics while not adding significantly to seat time is by deploying short-form training. And, according to the survey results, 44 percent of survey respondents are offering shorter courses—or plan to in the next year.

Program Effectiveness Measurement Becoming a Business Necessity

Measuring training effectiveness is the second most common training trend. Most organizations today struggle with measurement (see more in the “Measuring Effectiveness” section of this report), but demonstrating a compliance program’s effectiveness is becoming a business necessity—not only to understand where there are opportunities to improve the program, but to justify the program’s budget. Establishing what “effectiveness” means, determining how to measure it and then collecting and reporting on the data are the challenges that lay ahead for forward-thinking compliance professionals.

Increasing Focus on Middle Managers

In light of the concerns that respondents have about managers and their skills for handling complaints and supporting the culture, it is good to see that 45 percent of organizations plan to focus on deploying additional training specifically to middle managers. Often the first in the organization to be confronted with ethics and compliance challenges, middle managers remain key in the effort to build and sustain a culture of respect and integrity.



2) Focusing on Quality and EffectivenessFINDINGS: Quality matters. Nearly all (92 percent) of the survey respondents agree that quality of an online training course is critical to ensuring that training is effective. Maximizing effectiveness is critical for making the most of limited training hours and budgets—and truly impacting behavior and culture. For effectiveness, respondents lean primarily on high-quality video-based training.

Training Course Quality’s Impact On EffectivenessThe quality of an eLearning course makes a significant difference in training effectiveness.

Agree

Neutral

Disagree

0 10 20 30 40 50 60 70 80 90 100

Training Course Quality’s Impact On Effectiveness

92%

7%

1%

The quality of an e-learning course makes a significant difference in training effectiveness.

Strongly Agree Somewhat Agree

StronglyDisagree



2) Focusing on Quality and Effectiveness (continued)When evaluating online training courses for quality, the top two purchase criteria underscore the importance of quality. The first is the look and feel of the course: does it employ engaging and interactive content? The second is closely related—how often are courses refreshed? In other words, is it contemporary? Does it include the most relevant examples or do course references and content seem dated?

Instructional Media Format PreferencesWhich type of instructional media is most effective for the following objectives?

Animation Video-Based Training

0 10 20 30 40 50 60

Video-Based Training Slide with Audio No Preference

44%22%

7%28%

20%44%

9%26%

27%14%

10%50%

29%44%

7%19%

37%33%

9%21%

Video to AnimationPreference Ratio

2x

2.2x

1.9x

1.5x

1.15x

Establishes Credibility With Learners

Training Is Taken Seriously And

Considered Important To The Job

Favorable Judgment From A Judge,

Jury, Prosecutors Or Regulators In A Defense

Teaching Behavioral Principles In A Manner

That Changes Attitudes And Behavior

Learning Retention




2) Focusing on Quality and Effectiveness (continued)

eLearning Provider Selection Criteria

ANALYSIS: While “quality” may be a subjective term, respondents made it clear that they know it when they see it. High-quality online training is seen as superior when it is credible, fresh and relevant. Furthermore, respondents believe video-based training is the best form of instructional media for establishing a training program’s credibility, engaging employees, teaching behavioral principles and helping trainees retain information.

High-Quality Video-Based Training Helps Meet Increasingly Sophisticated Audience Expectations

In all these areas, respondents ranked video-based training above animation-based training and slideshows with audio. This preference for video may be due to increasing consumer sophistication and expectations for all media. These findings are in agreement with NAVEX Global’s experience as far as what training programs and formats have been most effective for our clients.

0 20 40 60 80 100

Significant Importance Moderate Importance Not Important

88%

80%

77%

68%

67%

66%

64%

62%

60%

42%

37%

81%

10%

17%

20%

27%

29%

31%

32%

30%

32%

44%

33%

16%

2%

3%

3%

5%

5%

3%

5%

8%

8%

15%

30%

3%

Look And Feel Of The Training Experience, Engaging And Interactive Content

How Often Courses In The Library Are Refreshed And Updated; Age Of Content

Customization Options

Reputation Of Vendor And Service

Modular (Content Modules Can Be Swapped In Or Out)

Availability Of Training Course Content In Both Long And Short Formats

Credentials Of Course Content Creators

Endorsement Of Respected Regulatory Bodies, Associations, Or Legal Entities

Training Provider Learning Management System (LMS)

Total Number Of Course Titles In The Library

Mobile Enabled

How Content Translated Into Other Languages Is Presented




3) Doing More With Less Covering more risk areas with limited hours and budgets is a priority for survey respondents. To address this, compliance professionals are adding course titles—and the titles they’re adding are increasingly short-form learning courses (three to seven minutes in duration) that focus training on a specific issue or critical update. Thus, organizations are adding risk coverage without adding significant training time.

Sixty-one percent of respondents believe short-form training is effective at covering more risks; 49 percent believe short-form training is an effective substitute for full-length courses in lower risk areas.

Effectiveness of Short-Form or “Burst Learning” Training

0 20 40 60 80 100

76%

Effectiveness of Short-Form or “Burst” Learning Training

5%19%

73% 4%23%

68% 5%27%

63% 6%31%

61% 8%31%

59% 10%31%

57% 7%36%

55% 9%36%

49% 15%36%

48% 17%35%

42% 12%46%

Effective Neutral Not Effective

of all respondents are

or will be using short-form training in the next 2-3 years

Raising Awareness

Reinforcing Foundational Training

Adding Variety To Instructional Methods

Covering Trending Topics

Covering A Greater Number Of Risk Areas

Reducing Time Employees Spend In Training

Encouraging Employees To Report Misconduct Internally

Generating Employee About Certain Topics

Substituting For Full Length Courses In Lower Risk Areas

Distributing Policies

Signaling Greater Sophistication And Rigor In Training & Awareness Programs


44%



3) Doing More With Less (continued)ANALYSIS: As noted earlier in the report, the number one training challenge cited by respondents is limited time available for training. Short-form training is being used by organizations to combat challenges they face in their training programs; 61 percent say it can help them cover more risk areas and 49 percent say short-form training can be used to replace some full-length courses.

Short-Form Learning Effective Format for Raising Awareness, Diversifying Training Mix and Reinforcing Key Messages

In general, respondents found that the short-form training format is most effective when used to raise awareness (76 percent), reinforce training lessons (73 percent) and generally diversify the mix of training methods (68 percent). Periodically reinforcing important lessons about key compliance risk areas is not only a best practice, but is also recognized by enforcement agencies as an important element of an effective training program. Due to its cost-effectiveness and lessened impact on seat time, short-form training is becoming a key training method.



4) Measuring EffectivenessFINDINGS: The top three effectiveness measures in place in respondents’ organizations today are: (1) Training completion rates, (2) unsolicited feedback from employees, managers or senior leaders and (3) results of learning retention quizzes. Almost three quarters of companies (72 percent)—regardless of organization size—measure training effectiveness using completion rates.

Approaches Used to Measure Training Effectiveness

72%

57%

55%

44%

48%

43%

42%

42%

1%

26%

20%

14%

0 20 40 60 80

Training Completion Rates

Unsolicited Feedback From Employees, Managers, Or Senior Leaders

Learner Retention Quizzes (Knowledge Of Concepts, Laws, Policies, Skills)

Changes In Behavior (Misconduct Observed, Reported, Or Substantiated)

Surveys

Report Data From Hotline, Ethics Office, Or Hr(Report Rate, Types Of Reports, Anonymity, Categories)

Changes In Attitudes

Learner Reaction/Response

Business Metrics/Results (Lawsuits, Investigation Duration, Turnover, Etc.)

We Do Not Formally Measure Training Effectiveness

Brand Reputation/Trust (Behavior Of Customers, Partners, Media, Analysts)

Other



4) Measuring Effectiveness (continued)ANALYSIS: Measuring effectiveness is one of the key trends that compliance professionals will be focused on over the coming year. However, the results of the survey demonstrate that organizations have significant work to do to create real effectiveness measures. The most-frequently used method—cited by nearly three quarters of all respondents—is measuring completion rates. While this approach is common, it only measures successful training deployment, not effectiveness.

Defining Key Performance Indicators Crucial for Success

To improve effectiveness measurement, organizations will need to establish key performance indicators (KPIs) for training programs. In conjunction with senior leaders, compliance professionals must define success and effectiveness, determine what tools they will use to measure against KPIs, and decide what portion of their budget they are willing to allocate to the measurement process.

The measures chosen should be driven by an organization’s goals for their training program. Such goals may be eliciting positive reactions or driving changes in learning, behaviors, results or ROI. Each goal will likely require a specific measurement method. Some of the tools that can be very important in the measurement process include pre-and post-training analysis through surveys, focus groups and changes in helpline and litigation data.


V. CONCLUSION & KEY TAKEAWAYS

ConclusionThe state of ethics and compliance training is rapidly evolving. Compliance professionals are broadening the focus of their programs beyond just establishing key legal defenses; program effectiveness now also depends on compliance professionals’ ability to create a culture of respect and prevent future misconduct.

Reaching these goals will require organizations to rethink and innovate the way they are training their employees. Compliance professionals will need to be increasingly focused on prioritizing and addressing top risk areas, and using short-form training to cover more risk areas even in the midst of limited training hours and pressured budgets. And, as they look to the future, leaders must be increasingly focused on laying the groundwork today to measure the effectiveness of their training investment tomorrow.

A balanced, thoughtful ethics and compliance training program is no longer optional—it is a cornerstone for organizations that are committed to building an ethical culture, and protecting their people, reputation and bottom line.

Key TakeawaysTo maximize training program effectiveness, compliance professionals should take the following steps:

− Focus on foundational training. The top two courses an organization deploys should be code of conduct training and harassment training, as these two courses address the biggest risks and set the standard of appropriate workplace behavior. The training delivered by these courses should be of top-notch quality.

− Thoughtfully match training to address key risk areas. No training program can tackle every risk area every year. Effective programs make data-driven decisions, planning out training curriculums and utilizing an array of training methods to drive home key messages.

− Insist on high quality training. Because the average organization only deploys a few courses a year, the quality of each course is more critical than ever in achieving ethics and compliance training effectiveness.

− Ensure training is relevant for each of your key audiences. Programs don’t just serve one audience, and each audience poses special risks to each organization. Ensure that your training speaks to each of their needs—with special emphasis on board members, middle management and third parties.

− Develop a plan to measure training effectiveness. Don’t simply let completion rates and anecdotal comments serve as program success determinants. Establish KPIs, allocate appropriate budget and put the processes in place today to measure the effectiveness of the training you deploy.

− Leverage short-form training. To cover more topics, manage seat time, add variety, raise awareness and reinforce critical training, utilize short-form training in your compliance training program.

− Incorporate a variety of training formats. Even if online training is the most frequently-used method for deployment, programs should use a variety of communication formats to reinforce training messages. Consider diversifying your training and awareness formats to include: live training, awareness materials, policy distribution systems, printed materials, intranets, etc. All are viable options and can be quite cost-effective when measured against the benefits of increased message retention.


VI. ABOUT THE AUTHORS & NAVEX GLOBAL

Mary Bennett, R.Ph., is vice president of advisory services and a pharmacist by training. She previously served as vice president in the Compliance and Integrity office at Caremark, where she implemented the requirements of one of the first government agreements in healthcare. Mary works across all industries for the advisory services team, creating and facilitating award-winning training programs, conducting large and small program assessments, developing compliance communications and helping clients develop best practice programs from the ground up.

Ingrid Fredeen, J.D., vice president of advisory services, has been specializing in ethics and legal compliance training for nearly 10 years. She has been the principal design and content developer for NAVEX Global’s online training course initiatives utilizing her 18 years of specialization in employment law and legal compliance. Prior to joining NAVEX Global, Ingrid worked both as a litigator with Littler Mendelson, the world’s largest employment law firm, and as in-house corporate counsel for General Mills, Inc. a premier Fortune 500 food manufacturing company.

ABOUT NAVEX GLOBALNAVEX Global helps protect your people, reputation and bottom line through a comprehensive suite of ethics andcompliance software, content and services. The trusted global expert for more than 8,000 clients in 200+ countries, oursolutions are informed by the largest ethics and compliance community in the world. More information can be found at www.navexglobal.com

Date post:	19-Aug-2015
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