Matt Silverman (matt.silverman@asml.com) is the Global Trade Director and Senior Counsel at VIAVI Solutions in Scottsdale, Arizona, USA.
Ideally, you want employees to absorb and retain the knowledge they’ve acquired throughout the course of any training program. But much of what is trained is forgotten (at least initially), and more importantly, retaining certain knowledge or facts doesn’t mean behaviors are necessary influenced. No matter how detailed, tailored, interactive, or entertaining a training program is, it may not be enough to truly influence an employee’s behavior, especially if it is simply assigned once a year (or once in a lifetime!) or capped with a quiz to test short-term knowledge retention. These avenues will most likely provide no evidence that the employee’s actions or behavioral changes have been influenced in the long term, nor that the overall compliance and ethics culture of the workplace has been affected.
In its determination of a well-designed and effective compliance program, the U.S. Department of Justice looks to whether a company has “evaluated the extent to which the training has an impact on employee behavior or operations.”[1] In other words, companies have a responsibility to not only provide training that makes an impact on employee behavior or operations, but to measure such impact.
So, how do you make training more focused on long-term behavioral and cultural change, and how can you measure the impact of your program?
Remind employees of their training—and keep reminding them
Training should not be a one-time event; it should be ongoing and take different forms. Maybe your training program begins with a standalone learning session (in-person or virtual) but is then followed up a few weeks or months later by an internal email blast, newsletter article, or “refresher training” (e.g., a shortened version of the initial training) to remind employees of concepts, actions, or responsibilities valued by the company. The purpose of repeated training and reminders is not to quiz employees on their long-term knowledge retention, but rather to continuously emphasize the expectations of the compliance and ethics department and management, which employees will then consistently recognize and/or exhibit these concepts, values, responsibilities, or behaviors on a day-to-day basis.
Employees who are given training once a year on ethics, safety, anti-bribery, export controls, sexual harassment, etc. without any follow-up or discussion afterward may come to interpret such training as a task to be completed, rather than an ongoing responsibility. Managers who find subtle or brief ways to stress the importance of certain concepts or values throughout the year (after the initial, formal training has been completed) may see such messaging outwardly manifested in employees’ action and behaviors. Maybe it’s as simple as placing posters around the office to remind employees of certain company values. Maybe it’s a happy hour pub quiz (again, not to test retention but to remind and imbed certain lessons or compliance concepts). A more straightforward approach may be necessary, such as an ethics announcement at the beginning or end of a weekly team meeting in order to remind employees of the importance placed on a specific ethical or compliant behavior. Such continuous training lends itself to consistent changes in individual employee behaviors and, over time, a shift in workplace culture.
