There may be people in your organisation who are specialists, and give guidance on what the rules are – but when it comes to ethics and compliance training, what employees need to know is how to identify a risky situation, how to behave when they do so and who to call if they have a question.

Good ethics and compliance training is therefore about behaviour – knowing how to do the right thing or where to seek advice if you are unsure. For most employees, it is not about knowing what Section 7 of the Bribery Act says, or even how a ‘dominant market position’ is defined. It is a common mistake in ethics and compliance training to teach the law – apart from communicating what the basic rules are, it is misguided and unnecessary to try to do so.

So who is typically responsible for training employees? (Surely the Legal Department or HR can do it?)

The responsibility for making sure employees know the rules varies from company to company. It can be:

The legal department

The compliance department

The ethics department


The procurement/purchasing department (especially where anti-bribery training is required)

IT (especially where data or IT security is involved)

The corporate/CEO’s office – for example where they are responsible for training on a company’s code of conduct

If you are a training provider, or even an employee looking to its employer for guidance on a particular subject, it’s clearly important at the outset to determine which department is responsible for a particular type of training and who the decision-maker/budget holder is. Don’t waste time talking to the wrong person!

In my next commentary, we’ll look at the relative merits of different types of ethics and compliance training.