How does a company know whom to train?
Any legal or compliance department worth its salt will know where the major risks lie in its particular industry, and who is likely to get things wrong.
It may have found this out by conducting formal or informal risk assessments.
It may be apparent that the way the company operates, its selling structures, its market shares, or its industry sector that problems of, say, competition law or corruption are likely to need addressing.
It may be in a company which has already suffered a particular compliance issue – such as an investigation by the competition authorities, an incidence of bribery reported to the Serious Fraud Office or a leak of sensitive information.
It may be operating in risky territories, particularly where bribery and corruption are endemic – such as Russia, China or Indonesia (Transparency International publishes a perceived corruption index, available on their website, listing challenging countries to operate in from this perspective).
Having identified where the risks lie, it will be relatively easy for the company to identify who needs to be trained, and by which method of training.
When is training required?
The short answer is regularly and often – but not so often that it turns people off.
It is typically required or appropriate when:
- An employee joins a company or moves department
- When a company’s code of conduct is rolled out
- When individual compliance policies are issued – e.g. competition law compliance, anti-bribery
- Key messages need to be refreshed, regaining an employee’s attention and reminding him that just because he took a course six months ago, the subject has not gone away
- When a company has suffered a compliance problem – no one wants to work for a company which has had its reputation scarred in the press – and will be keen to want to get things right next time.