Survey Confirms that Senior Management Embraces Quality Ethics Training - So Don't Just "Check the Box"

A recent survey by the Ethics and Compliance Officer Association confirms that senior management in America’s largest organizations “get it” when it comes to compliance, and that they are often the biggest drivers in compliance programs, such as enterprise-wide ethics training.

The survey focused on the anti-corruption programs at 165 multinational companies and looked at what the responding companies are doing – and why.

According to the survey sponsors, the anticorruption programs examined were not simply a reaction to the threat of lawsuits, or the hit to brand equity that usually results from a major compliance gaffe. Instead, responding companies reported that the programs were part of “a larger effort to build a culture of compliance within the company, one that is rooted …in the company’s system of values[.]”

Consistent with this conclusion, companies reported that their senior leaders were the single most influential driver for their programs. Programs were also much more widespread than in 2000, when an earlier survey was taken.

In many ways, the report simply confirms what I’ve seen in the field. The conclusion that may be more surprising to some of you, is that senior management does in fact care about compliance and ethics, and will support the steps necessary to create a culture of compliance.

It’s an important lesson for HR or legal professionals who may be tasked with putting together a company’s first compliance training program. These folks often set out to do the absolute minimum necessary – presumably out of a fear that they will be criticized for spending too much money, or for forcing people to take too much time away from work. The ECOA survey strongly suggests that this approach is short-sighted, and a big mistake. Compliance training programs have senior management’s support, and are recognized for the tangible return on investment they can bring to an organization.

So, the lesson is, an HR or legal professional looking to buy an ethics training program should focus on choosing a high quality solution that can best support a robust compliance program.

The ECOA survey also strongly demonstrates that the bar is being raised when it comes to the legal ramifications of your compliance programs.

The survey’s authors concluded that the programs they reviewed had become significantly more detailed and sophisticated in the last six years. With judges and regulators becoming more savvy about compliance issues, “check the box” solutions no longer maximize legal protections, nor are they looked upon favorably.

Imagine the look on the face of a judge when you argue that you are truly committed to compliance – even though you provided rudimentary ethics training, or even worse, no training at all.

At the end of the day, the survey simply confirms what common sense tells us. If you’re going to invest the time and effort necessary to create a compliance training program, choose training that you feel will truly reach your learners, and maximize your legal protections. It’s a strategy that gives you the best chance of pleasing senior management -- and the judge.

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