CEP Magazine - April 2021 Hosting effective compliance trainings in a virtual classroom - COSMOS Compliance Universe
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CEP Magazine - April 2021
Hosting effective compliance trainings in a virtual classroom
By Patricia Marinho and Emanuel Batista
Patricia Marinho (patricia.marinho@willistowerswatson.com) is a Compliance Director, LATAM, for Willis Watson Towers in
Miami, Florida, USA. Emanuel Batista ( ebatista@kroll.com) is an Associate Managing Director in Kroll’s Compliance Risk and
Diligence practice in Washington, DC, USA.
In today’s working environment, employees are unable to walk down the hall and stop by a colleague’s office to
exchange ideas about a project. As a result, the number of meetings at some organizations has substantially
increased. In an attempt to stay connected, management has increased the number of meetings and trainings
being conducted, and as such, the potential for lack of interest and participation by some employees have become
a common theme in corporate environments. In April 2020, only a month into the pandemic, Microsoft reported
a new daily record for meetings held on its virtual meeting platform: 2.7 billion meeting minutes in one day,
which represented about a 200% increase from the previous high of 900 million minutes.[1]
These same risks are associated with mandatory employee trainings that organizations conduct to give
employees the guidance they need to perform effectively and to enable them to comply with regulations and best
practices. By including too many people, covering too many topics, and holding prolonged training sessions,
companies risk hosting trainings that are not focused or tailored to their goals and do not provide thought-
provoking, relevant information that enables employees to achieve established goals and objectives. This article
seeks to provide insights on how to conduct more effective training sessions and generate employee engagement,
stimulate conversations within an organization, and highlight the importance of providing risk-based content in
the era of virtual meetings.
Know your audience to tailor your training
It becomes even more important for compliance officers to understand their audience and its familiarity with the
topics to be addressed when preparing to present virtual trainings. When conducting an in-person training
session, compliance officers are able to “feel the audience” and assess its understanding and interest of the topic
by paying attention to the nonverbal communication. The emotional and human interaction during an in-person
training can be diminished or lost when the training is not well prepared. The use of visuals, presentations, video
clips, and even examples to support the importance of a compliance topic being discussed need to be bolder,
bigger, and better to keep the audience engaged.
As such, presenters must consider if the audience already has expertise on the topics, or if some audience
members are new to the organization and learning about the topics for the first time. With an understanding of
the participants and their levels of knowledge, a presenter can lead a discussion in an innovative way that will
also engage those who are already familiar. Audience members who are also experts on a topic can be called to
provide their thoughts and real-life examples of how they have used the information being discussed to make
ethical business decisions.
Understand different learning styles to customize delivery
Copyright © 2022 by Society of Corporate Compliance and Ethics (SCCE) & Health Care Compliance Association (HCCA). No claim to original US
Government works. All rights reserved. Unless permitted under this website’s Terms of Use , this content may not be reproduced, duplicated,
copied, downloaded, stored, further transmitted, disseminated, transferred or otherwise exploited without SCCE & HCCA’s prior written consent.
-1-Some people learn best by listening, others by doing or seeing. Accordingly, compliance training should consist
of varied methods of instruction that engage diverse learning styles. Videos, case studies, and graphs should be
eye-catching and contain thought-provoking information that will provide a different perspective on the subject
being addressed.
Alternatively, role-playing different scenarios may present different perspectives to help participants
understand topics such as managing third-party relationships and compliance hotlines. For example, a
presentation on the importance of vetting third parties to avoid reputational risks to an organization can include
real-life examples of organizations that have experienced this issue, using news media articles and short video
clips, in addition to an overview of the company policy and position on the topic. The presenter can then elicit
feedback from the audience on the root cause of the problem, how the organization could have prevented it, and
the role of compliance policies and procedures in preventing and mitigating such issues.
The output at this stage should result in the audience thinking about compliance daily, its impact to the
organization, and how to execute against it.
Think ahead to avoid confusion before and during the session
A Harvard Business Review article[2] on the art of creating the perfect meeting agenda advised that more often
than not, agendas are just recycled from meeting to meeting and fail to inspire employee participation. The same
can be true for annual training agendas: If they are not customized and do not provide the big picture of the
importance of the training, employees may see little value in the information being shared.
To that end, we have all been unsure at one time or another of whether our attendance at a meeting or training
was required due to the lack of information provided. To avoid this confusion and effectively communicate that
attendance is indeed important, you must set the tone, requirements, and goals for the training in all
promotional materials and invitations. Any prerequisite, such as material that needs to be read or activities that
need to be performed before the training, needs to also be clearly stated in the invitation.
We’ve also become familiar with training seminars during which technical difficulties prevented us from starting
on time or made it difficult for the audience to understand the content due to poor audio quality, a slow internet
connection, or even a malfunctioning headset. Technical difficulties are bound to happen. Thus, it is best to be
prepared in advance and ensure participants are ready by confirming they have working microphones and high-
speed internet connections. One should also request they join the meeting a few minutes early, if possible, so the
session can start on time and any technical difficulties can be addressed prior to the meeting.
Make your training materials relevant and engaging
A successful training session needs to be risk-based, tailored to the audience, and have the right amount of
content so it will be understood by the audience. The training should not be text-heavy and overloaded with
information on only the company’s compliance policies and procedures. Should the presenter choose to use a
PowerPoint presentation to share the agenda and main topics, the slides should contain short phrases that guide
the training, rather than detail the full company policy relating to compliance requirements. Always keep in mind
that people read what is presented to them, so the presenter may lose audience members who are reading ahead
or who feel overwhelmed by the details on the screen.
Real-life examples of compliance issues and their outcomes should be provided to the attendees for the training
to be most effective. Rather than just using words, it is always important to also include graphs, statistics, and
other illustrations that support the examples.
Copyright © 2022 by Society of Corporate Compliance and Ethics (SCCE) & Health Care Compliance Association (HCCA). No claim to original US
Government works. All rights reserved. Unless permitted under this website’s Terms of Use , this content may not be reproduced, duplicated,
copied, downloaded, stored, further transmitted, disseminated, transferred or otherwise exploited without SCCE & HCCA’s prior written consent.
-2-Consider sharing the slide deck prior to the training to allow participants to familiarize themselves with the
information, rather than sharing new information at the session and soliciting feedback right away. This
approach can generate additional interactions and enable audience members to come to the meeting with any
questions they may have. However, do not expect everyone to read the deck beforehand if it is not clearly stated
as a requirement. Even more important than sending the information beforehand is sending a post-session
email that includes the supporting materials used during the session and directions on where to find them within
the organizations shared drive so employees can use them as reference guides in the future.
Ideas for hosting more engaging training sessions
It is a good idea overall to motivate employees to turn on their cameras to increase participation and
engagement. Without the use of their cameras, employees may start multitasking without putting themselves on
mute—this is when training participants hear angry typing and get distracted from the discussion. Though in a
virtual classroom, the body language from both the presenter and the audience still strongly indicates levels of
engagement; indicators of high engagement include good posture, direct eye contact, and positive nonverbal
responses to the topics being addressed. Another point to consider is while working from home over the past
year, every day has become “Casual Friday,” so to avoid surprises during video training sessions, it is important
to inform employees about acceptable dress codes for an event.
Hosts of training sessions may find a more hands-on training session to be successful, wherein employees
participate by responding to questions via polling or instant messaging and by just sharing their thoughts and
own examples. Rather than simply sharing the company’s written statements about anti-corruption and bribery
policies, for example, invite a company’s CEO or a member of senior management to a session to demonstrate
the importance of compliance, the company’s commitment to it, and the organization’s perspective that it is not
viewed as an expense but as an investment in safeguarding the company’s reputation.
As mentioned previously, to engage audience members with varying levels of familiarity of a topic, it can be
advantageous to present role-playing scenarios that involve a few members of the audience. A role-playing
scenario allows employees to interact while presenting a situation and to ask the broader audience about
compliance issues, how they are managed, and how they could have been prevented. The responses to these
points provide critical feedback to the presenter on how the subject matter is viewed and executed against.
Another strategy to consider involves dividing the audience into competing teams and awarding points for
participation or for correctly answering the highest number of questions. Awards can include bragging rights or
low-value prizes, such as a gift certificate for an online food delivery platform.
Make the content risk-based and relevant
Due to the lack of in-person interactions during virtual trainings, it is crucial that the training content is still
thought-provoking, engaging, and relevant to the job roles performed by the audience members to ensure high
engagement and long-term effectiveness.
In June 2020, the U.S. Department of Justice (DOJ) Criminal Division updated its recommendations on the
Evaluation of Corporate Compliance Programs,[3] dedicating an entire section to training and communication as
one of the hallmarks of an effective compliance program. The DOJ emphasized that an effective program includes
risk-based employee training prepared for relevant control functions that address potential instances of
misconduct in an organization. The guide also advised on questions about the preparation of content, the
method in which the training is executed (either online or in person), and the training’s rationale.
Additionally, the guide addressed the management of global teams, highlighting the importance of training
Copyright © 2022 by Society of Corporate Compliance and Ethics (SCCE) & Health Care Compliance Association (HCCA). No claim to original US
Government works. All rights reserved. Unless permitted under this website’s Terms of Use , this content may not be reproduced, duplicated,
copied, downloaded, stored, further transmitted, disseminated, transferred or otherwise exploited without SCCE & HCCA’s prior written consent.
-3-employees in the local language. Its objective is to enable audience members to maximize their understanding of
the content and to increase the availability of the compliance department to address questions and to maintain
an open channel of communication. When managing a global team, it becomes even more important to design
compliance training customized to different departments, with real-life examples about misconduct and best
practices that are relevant to the audience. Lastly, all training information, company policies and procedures, and
other guidelines must be made available to all employees in a centralized location.
Whether a training is held virtually or in person, it is critical to measure the effectiveness of compliance
curriculum to ensure that it remains relevant; provides insight into the company’s stance on bribery and
corruption; and includes updated information on regulatory requirements, industry trends, and recent case
studies. To measure the training’s effectiveness, employees should be tested on their knowledge of the material,
and the company should certify and document employees’ completion of compliance trainings. The certification
process can be handled online by the completion of short quizzes addressing main topics of the training session
along with online signature platforms to obtain executed documentation confirming employee participation,
awareness, and compliance with the company’s policies and procedures. Even with this certification, it is the
individual employee’s responsibility to act in an ethical manner when conducting business on behalf of the
organization they are employed by even when no one is watching.
Customized training leads to empowered employees
Today’s training opportunities must be balanced against an organization’s commitment and culture of
compliance to ensure that training opportunities provided are not viewed as check-the-box exercises or as an
off-the-shelf training solution solely designed to comply with regulatory requirements. Training sessions are
meant to provide employees with the tools to be committed to the company’s culture of compliance and detect,
prevent, and escalate compliance issues to compliance officers when they arise during the course of their daily
business operations. Appropriate training should serve to educate, drive, and prevent compliance challenges
within an organization’s workforce if the approach and content are effective in addressing, mitigating, and
preventing risk.
The challenge of operating with limited in-person engagement continues in this new reality of virtual training
and meetings, but by thinking ahead about the audience and the true purpose of the training session, enjoyable
and valuable information regarding best practices and compliance with company and regulatory requirements
can be effectively achieved. It is not the length or frequency of trainings that makes them effective but their
ability to deliver impactful information that employees can use to do their jobs and ensure compliance with the
multitude of requirements they are posed with. At the end of the day, an effective virtual compliance training
program should empower employees to be well informed and make ethical decisions, and enable the company to
achieve a culture of compliance within its enterprise.
Takeaways
It is important to gauge the audience’s different learning styles and expectations of the session topics to
provide engaging and thought-provoking training.
Set the tone of the training in your invitation.
Take steps to prevent potential technical difficulties that could occur during the event, and have a backup
plan should issues arise.
Provide customized and risk-based content that not only satisfies regulatory requirements but reinforces
Copyright © 2022 by Society of Corporate Compliance and Ethics (SCCE) & Health Care Compliance Association (HCCA). No claim to original US
Government works. All rights reserved. Unless permitted under this website’s Terms of Use , this content may not be reproduced, duplicated,
copied, downloaded, stored, further transmitted, disseminated, transferred or otherwise exploited without SCCE & HCCA’s prior written consent.
-4-the company’s culture of compliance and its commitment to regulatory obligations.
Offer employees in your training the tools and guidance needed to help make compliance part of their work
performance.
1 Jared Spataro, “Remote work trend report: meetings,” April 9, 2020, http://bit.ly/2YJqydy.
2 Steven G. Rogelberg, “How to Create the Perfect Meeting Agenda,” Harvard Business Review, February 26, 2020,
http://bit.ly/39L0uVZ.
3 U.S. Dep’t of Justice, Criminal Div., Evaluation of Corporate Compliance Programs (Updated June 2020),
http://bit.ly/2Z2Dp8R.
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Copyright © 2022 by Society of Corporate Compliance and Ethics (SCCE) & Health Care Compliance Association (HCCA). No claim to original US
Government works. All rights reserved. Unless permitted under this website’s Terms of Use , this content may not be reproduced, duplicated,
copied, downloaded, stored, further transmitted, disseminated, transferred or otherwise exploited without SCCE & HCCA’s prior written consent.
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