Compliance officers spend a significant portion of their time on employee training: either developing material for training or going into the field to lead training.
There’s also a third duty critically important to the success of your compliance program—keeping track of employee training, so you know how well those first two duties are working and where you might need to adjust.
No less an authority than the Justice Department’s guidance on effective corporate compliance programs mentions the importance of managing employee training wisely. It lists several questions prosecutors might ask about training programs, including:
- Has the training been offered in the form and language appropriate for the audience?
- Is the training provided online or in-person (or both), and what is the company’s rationale for its choice?
- How has the company measured the effectiveness of the training?
- Have employees been tested on what they have learned?
- How has the company addressed employees who fail all or a portion of the testing?
There are no right or wrong answers to those questions, but compliance officers do need to be able to provide answers. And in one way or another, answering the above questions depends on how well you can track employee training. So let’s consider several ways to track that training. Then we’ll explore what a compliance officer might do with the insights that tracking can bring.
Metrics to Track Employee Participation
First, compliance officers simply want to track the extent to which employees are taking their compliance training. You want to follow metrics such as:
- Completion rates: How many employees do actually complete the training courses you send to them? (This could be how many people complete online training courses, or how many show up to in-person classes.) For required training, such as for anti-bribery or anti-harassment issues, the completion rate should be 100 percent.
- Time to completion: How much time elapses between you telling the employee to take training (“Please take this online course within two weeks,” or “Please register for one of our upcoming sessions”) and when the employee actually does finish that training?
- Success rates: How many employees actually pass whatever test your training includes at the end?
Ideally, you will track all three metrics by important population segments in your company: by the department, geographic location, job level, and so forth. The more granular you can get in the collection of this data, the better.
These participation metrics can help you answer several of those Justice Department questions above about employee training. For example, if you see low completion rates or high failure rates in certain markets, that might be because employees aren’t familiar with the language your training materials use. If online courses generate higher failure rates than in-person classes, maybe you should reconsider the format you use.
Participation metrics show how your employees are interacting with your training program. Over time, you can collect enough data to draw conclusions about how the training program works at the practical level; and then you can course-correct as necessary to improve.
That thoughtful sort of approach to training is exactly what the Justice Department and other regulators want to see.
Metrics to Track Employee Engagement
Aside from those more practical issues about delivering training, compliance officers have another concern: whether the training actually changes employee behavior. Several other metrics can help answer that question.
- Changes in internal reporting: If you launch new training on anti-bribery, anti-harassment, or other issues, do you see changes in what employees report up through internal reporting channels? That could be a spike in hotline reports about improper payments, more complaints to HR about abusive managers, or just questions people ask their managers.
- Changes in how people use your Code of Conduct: If your company has an interactive Code of Conduct, or uses an app or intranet to let employees search corporate policies—do you see changes in what they’re searching for?
- Changes in employee surveys: Surveys of corporate culture, or employees’ observation of misconduct, should be a regular part of compliance program operations. If your training is achieving its objectives, that should lead to new employee perceptions and attitudes about the company’s culture of compliance.
One point to remember: Metrics of engagement evolve on their own schedule. You can hope for changes in employee attitudes or what gets reported via the hotline, but you won’t know precisely when those changes will emerge, or how pronounced the changes will be.
Yes, you can (and should) benchmark changes within your enterprise against similar organizations. That can help you get a sense of what’s “normal” for businesses like yours—but in this realm, “normal” is a range that can encompass lots of variation. What’s right for your company is something only senior executives can decide.
The Importance of Data in Employee Training
These six metrics also call out another point: compliance officers need a system to track all this data, and then study it to understand what the data tells you about your training program.
First, consider some sort of Learning Management System (LMS) to track participation rates—and to break that information into specific segments, so your assessment of the training program can be more precise. The LMS will also need to track key metrics over time.
Second, you still need to correlate that data with other information that measures engagement: internal reporting metrics, the results of employee surveys, and so forth. Those metrics will be generated by different systems and exist in different formats. So your ability to draw insights about how well your training program works and where you might improve—that will require capability in data analytics, too.
What regulators want to see when reviewing compliance programs is a thoughtful approach to employee training. They want to see that your existing training program has a logic to it and that you are at least trying to measure effectiveness so you can improve.
That requires you to measure both participation and engagement and to infer possible improvements from what the data tells you. With the right metrics and analytics, you’ll get there.
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