A compliance program built on a “check-the-box” approach is doomed because it isolates program elements that need to be integrated.  Compliance is akin to holistic ideologies (yes, you can quote me on that one).

The whole of a compliance program cannot be stitched together.  Each piece is interconnected in a greater whole.  Each piece of a compliance program is interdependent and reinforces the other pieces.

Turning away from my fluffy expressions and addressing the practical realities of a compliance program, what do I mean?

CCOs make a drastic mistake when they build a compliance program element-by-element without interconnecting or leveraging operations into each other.

For example, and the purpose of this posting, consider how training program are put together.  Live programs are built with slide presentations, maybe a handout and then begging sales directors or country managers time at a sales meeting so that the CCO can conduct a training program.  In some cases, CCOs are given the authority to schedule and implement a training program without approval or agreement by the sales director or staff manager.

Once a CCO determines how many live programs can be conducted they will enlist the support of an on-line training program to build out the training program to a satisfactory level.  This is nothing more than a check-the-box approach to training.

Let’s go back to the drawing board.

First, training is a critical communications opportunity.  The CCO has a chance to meet face-to-face with staff, many of whom are directly involved in risky interactions with foreign officials.  It is an important opportunity to spread the message of ethics and compliance, to communicate the tone of the company, and the priority of ethics and compliance.

It is also an important opportunity to listen and hear the sales staff’s concerns.  The CCO should always ask a sales staff group – “what do you need to do your job?”   The CCO should then listen to the answers.  CCOs have to avoid talking at people and instead listen to people.

A training program is, by definition, a captive audience.  It is a great opportunity to communicate the message of ethics and compliance.

Forward-thinking companies will enlist the support of senior management to conduct training sessions.  In other words, the CCO will training senior managers to conduct their own training sessions on ethics and compliance.  The message then is very powerful – senior management takes compliance seriously and will actively participate in training by conducting training sessions and talking directly to sales staff and other employees who engage in risky interactions.

Similarly, plugging in pre-packaged web-based training programs without any branding or specific messages from the CCO is a lost opportunity to communicate the company’s commitment to ethics and compliance.

A company’s culture can only be created with a consistent message that is reinforced at every opportunity.  Training is a critical component to communicating a company’s culture.