Training is not just another part of every C&E program; it is generally the part that touches the work lives of more of a company’s employees than do other elements. It should therefore be a significant focus of any program assessment.
The possible avenues of inquiry here are broad, as one would imagine, and each assessment will have its own areas of particular focus. But a partial list of core training assessment questions might include the following.
Plan. Is there a written plan for providing training on an annual or other periodic basis?
Risk-based. Are the training curriculum and content based – whether formally or not – on an assessment of risk? Is the risk assessment designed to be helpful in this regard?
Role of the Board. What training does the Board receive regarding its oversight of the program? What training does the Board receive regarding its own compliance risks?
Role of senior management. Are senior managers trained on the C&E risks and responsibilities applicable to their role at the company? Does this include their duty to support an ethical culture?
Supervisors. Is there C&E training for supervisors regarding their obligations to support the program and how to do so?
Other roles. Is other training appropriately role based? (E.g., is anti-corruption training adapted to different roles – such as internal audit, finance, sales and marketing, government relations and logistics?)
Participation. Is training that is supposed to be mandatory in fact treated that way? What is done to encourage stragglers to take required training? For in-person training, is a sufficient record kept of attendance?
Media. Does the company have a good blend of in-person and computer-based training?
Content. Is the information in the training accurate, comprehensive and clear?
Quality. Is the training engaging? Is it memorable? Too long or too short? (Note that one way to make training memorable is to use – as appropriate – “case studies” based on actual events at the company.)
Repetition. Is the same training program shown to employees more than once? (While some degree of repetition is acceptable and maybe even be desirable, too much of the same thing can send the wrong message to employees.)
Short programs. Does the company use short training programs to refresh employee awareness of key C&E topics?
Translations. Have they been done for all of the company’s principal languages? Is the training “US centric”?
Feedback. Does the company seek comments and suggestions from employees on the training?
Integration plan. Does the company have a plan for rolling out training to newly acquired entities? Is there a sufficient C&E component to the new hire onboarding process?
Third party training. Does it reach the right (i.e., high risk) third parties?
We should emphasize that – like all posts on this blog – the above does not aim to be comprehensive. However, we do hope it is helpful.