This report has been written by Towards Maturity, building on its
extensive benchmark research since 2003 with over 2200 organisations.
Commissioned by SAI Global
Download and share: www.towardsmaturity.org/in-focus2013/compliance
June 2013
Reinvigorating
Iain McLeod, Regional Director (EMEA), SAI Global Compliance
Foreword by Iain McLeod, SAI Global
There’s no doubt that some compliance training has acquired a bad reputation, often branded as dull and a bit of a chore for those on whom it is ‘imposed’. But does it really deserve such bad press? As providers to the industry, we are the first to acknowledge that there are some extremely poor examples of compliance e-learning inexistence, which unfortunately perpetuate this pre-conception, tarring all compliance e-learning with the same brush. If you’re responsible for your organisation’s compliance programme, this represents a serious problem for you, as it is a major contributor to the biggest barrier to compliance training effectiveness - lack of employee engagement.
However we know from experience that when done well, compliance e-learning can prove to be extremely effective, drive positive
behavioural change, deliver measurable results and play a crucial role in your overall compliance programme.
The purpose of this study is to investigate the current practices that contribute to compliance e-learning’s poor reputation and provide some food for thought about what you can do to overcome this.
Towards Maturity’s 2012 Benchmark Report revealed some interesting insights into the adoption of e-learning for compliance. The most striking fact to emerge was the significant gap between the benefits and efficiencies that companies expect compliance e-learning to deliver and their ability to consistently achieve against these expectations. SAI Global commissioned this research as we were keen to dig deeper into this revelation to understand why this gap exists and why existing implementation strategies and content (whether developed in-house or by third party vendors) are failing to deliver on expectations. We also wanted to identify the good practices being employed by those organisations which are more successfully delivering against their compliance learning objectives.
The findings are revealing and thought provoking and I invite you to read and digest them – and ask yourself how much of what you read you recognise in your own practices. I would like to highlight a couple of key themes that are prominent in this report and which based on our own experience are key to getting things right in the future: • Universally, lack of employee engagement emerged as the biggest barrier to effectiveness – and is linked
strongly to the poor reputation of compliance e-learning. Ask yourself what efforts you are currently making to really engage your audience and make it relevant to them. If you are subjecting your employees to ‘death by PowerPoint’, rolling out the same content year after year to everyone regardless of their job role or risk profile, blinding the learner with irrelevant detail about what the law says rather than what it means to them or failing to engage your line managers in the process, then the chances are you are
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• Compliance training is different to other training – well, we would say that wouldn’t we!? But the topic itself does present certain challenges that don’t exist for example with soft skills or other business skills training. Compliance is riddled with ‘grey areas’ and has to equip people to make the right decision in any number of situations that are not always simply black or white, right or wrong. For example, is it ever acceptable to accept tickets to Wimbledon from a supplier or could that be construed as bribery? What information is it acceptable to exchange with competitors and when would information exchange actually constitute a breach of competition law? Instructional approaches that work for other training topics may not be most effective for compliance topics. In our experience, you have to use techniques, interactions and scenarios that challenge existing attitudes and give employees the opportunity to ‘practise’ online so they understand how a risky situation could present itself, how it could evolve and see the consequences of a poor decision in a safe environment.
As a final thought, regardless of the preconceptions surrounding compliance e-learning and perceived preferences for format, delivery and implementation techniques, this study unequivocally demonstrates that the majority of organisations are not consistently delivering on their very high expectations and falling short on their goals. We can learn from the examples set by the more mature organisations, but overall the key message is that businesses have to question the status quo and change the way they are ‘doing’ compliance training if they are to bridge the gap between expectation and achievement.
I’d like to thank Towards Maturity for their support in working with us to investigate this increasingly important topic.
Iain McLeod Regional Director (EMEA)
Contents
1 Summary ... 6
2 About this research ... 7
3 The hopes and realities of technology-enabled compliance training ... 12
4 The benefits of using technology to deliver compliance training ... 17
5 Thinking differently about methods /media/blends ... 22
6 Thinking differently about your audience ... 29
7 What does good look like? Aspects of implementation ... 31
8 The future of compliance training ... 36
Appendix ... 39
About SAI Global ... 40
About Towards Maturity ... 40
This report was commissioned by SAI Global, who also helped to shape the research.
Authors: Laura Overton, Genny Dixon
© Copyright Towards Maturity CIC 2013. All rights reserved. No part of this material protected by this copyright may be reproduced or utilised in any form, or by any means, electronic or mechanical, including photocopying, recording, or by any information storage and retrieval system without prior authorisation.
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Re-invigorating Compliance Training - Key Findings
98%
of organisations want technology-enabled compliance training to help manage risk more
successfully
11%
of organisations know how much they spend on compliance training
12%
of organisations say compliance training is helping achieve their business goal of changing
working culture
23%
of businesses are raising awareness and understanding of complex regulations with
compliance training
67%
of organisations say user engagement is the top barrier to adopting technology enabled
compliance training
More mature organisations are
75%
more likely to report a positive impact on staff behaviour
than average
81%
use learning courses created in house to deliver compliance training
More mature organisations are
40%
more likely to think about the business problem before
recommending a solution than average
8%
of L&D professionals collect individual success stories and communicate them back to users
20%
of organisations include opportunities for staff to practice
20%
of organisations provide managers with resources and job aids to encourage application
back in the workplace.
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1 Summary
Compliance training is viewed by organisations as an area in which technology can deliver a big win. Why have face to face sessions when you can provide engaging, cheaper and more personalised content online? Well, that's the promise. But does e-enabled learning content deliver on that promise?
That's what this report aims to find out. Online compliance training is often criticised for being little more than a box ticking exercise. It is seen as a necessary evil due to the fact that most businesses have to ensure their employees are compliant with industry-specific regulation.
In this report we lift the lid on how organisations are using technology enabled learning to deliver compliance content that leads to behaviour change. We examine what organisations are currently doing with their compliance training programmes and how successfully L&D and risk and compliance professionals feel these programmes are performing.
Filtering the data by the level of organisational maturity at using technology enabled learning enables us to provide insights into what good training looks like. The findings are revealing: more mature organisations are more than twice as likely to change working culture than those in the less mature category and 75% more likely to report a positive impact on staff behaviour.
By comparing what more mature organisations are doing against their less mature counterparts, we are able to identify the steps to creating effective online compliance training. We have also dug deeper into the data to provide insights from compliance and risk managers and those in multinational organisations.
Some 90% of organisations see technology enabled learning as the answer for delivering compliance training. We hope this report will help dispel some myths around compliance training delivery and help convert the potential into effective, behaviour changing learning experiences.
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2 About this research
The 2012 Towards Maturity Benchmark shows that nearly 90% of organisations want to use learning
technologies to help improve efficiency in delivering compliance training. This has prompted us to dig deeper into this contentious area of learning and development.
We have captured data from 136 organisations with over 2.3m employees across 17 nations, which has given us deep insight into organisations of many sizes working across many countries. We have also scaled respondents according to their maturity in using learning technologies to deliver compliance training. This has enabled us to share insights into the approaches taken by more mature organisations and the results they are experiencing. With most organisations in the study having to undertake compliance training on at least an annual basis, it is perhaps surprising that most organisations either do not know or have no specific budget to spend on it. This would suggest that for most organisations, budgeting is more of an art than a science.
Why is it time to revisit compliance training?
Compliance training is an area that takes up much of our time – Learning and Development can continue to talk a good talk but we are focussing on measuring the ticks not tackling the issues of changing behaviour. Workers are being flooded with bad training that is not delivering, and worse, it is putting them off online learning for life! For too long staff have been subjected to dull, repetitive tick in the box compliance training rather than
experiences that encourage behavioural changes in business. For topics that are so essential for risk mitigation and business survival, we believe it's time to rethink our approach to compliance training before it's too late.
Every organisation has to comply with regulations, policies and procedures, and for some this will literally be a matter of life and death (such as oil and gas or health sectors). For other heavily regulated sectors, such as finance, the ability to demonstrate compliance is an essential factor for companies to operate. Even where such
compliance is not required by external regulators, companies still mandate certain training, such as adhering to the values and culture of the organisation and ensuring safe and healthy staff.
The evidence is mounting
Over the last 10 years, our own studies show that compliance related training is often the first foray into online learning. Previous studies have shown that 9 out of 10 of organisations are delivering some form of compliance training. In fact in 2012 the Towards Maturity Benchmarkshowed that over 50% of compliance related programmes are e-enabled in some way and nearly 90% of us want learning technologies to help improve efficiency in delivering compliance. Yet, despite this focus, only 50% believe that online compliance training is delivering the efficiencies we are looking for, let alone the behaviours.
This independent study was commissioned by SAI Global and is being carried out by Towards Maturity, a not for profit benchmarking practice, and builds on their benchmark research over the last 10 years with 2200
organisations. It was designed with input from independent experts and practitioners1. It explores the drivers, barriers, benefits and trends in the use of learning technologies2 in compliance training to understand what is
working well and what is not. It also investigates the methodologies used for carrying out compliance training and provides an action plan for increasing effectiveness and improving staff engagement.
Whose perspectives have we captured?
The 2013 Compliance study was open to all to take part in an online study between March and April 2013. Participants in the 2012 Towards Maturity benchmark who had indicated that they e-enabled their mandatory or compliance-related training were invited to take part and invitations were also extended to companies across Europe.
148 people with responsibility for either compliance or learning and development took part. They represented 136 organisations with, between them, over 2.3m employees.
• 57% were from the UK, although a total of 17 nations were represented • 65% of respondents were senior managers in their organisation
Respondents were spread across many industries, although there was a strong input from those in the financial services sector, health and social care and manufacturing.
Figure 1 Sectors represented in the compliance study
Over the past ten years of research into effective learning practices, Towards Maturity has found that those who have thoroughly embedded technology into all aspects of learning and development and are well aligned with the goals of the business, are achieving significantly higher results than most.
In this study, we asked respondents to self assess their e-maturity on a 5-point scale, in order to dig a bit deeper into what the mature organisations are doing differently and if they were achieving better results in the field of compliance training.
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Figure 2 Distribution of respondents across the five e-maturity categories
The number of respondents in this study were not sufficient to be able to present a detailed analysis of differences at this level of granularity, but we are able to compare those who are Less Mature (Novice, Sporadic or Developing categories) versus those who are More Mature (Established or Embedded categories). You will see comparative data for ‘More Mature’ and ‘Less Mature’ organisations included in tables throughout this report.
We were also interested to discover whether there was a difference in perspective between those with
responsibility for Compliance and Risk, and those who were in Learning and Development for whom compliance-related training was just one aspect of their wider portfolio.
• A total of 41% had primary or some responsibility for Compliance and Risk Management • 81% had primary or some L&D responsibility
The compliance and risk managers were drawn from all industries and nations but were predominantly from larger or multinational organisations (70%). We compare responses of L&D professionals with those of compliance professionals and those in multinational organisations only when those differences are interesting or significant.
The state of compliance training in Europe
A large majority of organisations represented in this report deliver compliance training using learning technologies. In this study:
• 87% participate in compliance training each year
• 77% use technology in this training (51% in the 2012 benchmark study, rising to 94% of those in the more mature group) 0 10 20 30 40 50 60 70
Novice Sporadic Developing Established Embedded
Novice We know very little about learning technology with only occasional use Sporadic Our use is localised or sporadic (used in
some departments or for some compliance training)
Developing We are developing and coordinating our use of learning technologies Established They are established across the
organisation and transforming the way we manage learning and development Embedded Learning technologies are thoroughly
Compliance-related training can be mandated internally or by external regulators and both are investigated in this study:
• 44% of the training is mandated by external regulators • 72% is mandated internally
What drives compliance training?
Health and safety and data protection are the key organisational risk domains for compliance training. However, our research shows this is just the tip of the iceberg, with a whole range of subjects now the focus for compliance training.
Figure 3 Risk domains driving learning and development activity
Other risk domains cited by respondents include: • Corporate compliance o Brand recognition o Business continuity o Dignity at work o Environmental awareness/management o Export Controls o Induction o Insider trading o Antitrust o International Trade
o Management policies and procedures o Safeguarding children and vulnerable
adults
• Regulatory compliance
o FAIS, Code of Banking Practice o National Credit Act
o Consumer Protection Act, o Market Abuse, Food Safety Fraud o Lending regulations
o Healthcare compliance
o Installation/Maintenance of Medical device
o Complaint handling
o Social and health care / Social care law
0% 10% 20% 30% 40% 50% 60% 70%
Competition law Anti money laundering Conflicts of interest Equality and diversity Information security Anti-bribery/anti-corruption Code of conduct Data protection and privacy Health and safety
Allocating budget
Budgeting for compliance training appears to be a dark art. Although organisations know where they intend to spend their budgets, less than 10% could provide a figure for their annual compliance training spend. Only 11 respondents could estimate a number – with an average of £178,000 pa.
More interestingly, most organisations either do not know, have no specific budget for this, or left this question blank. Judging by responses, organisations approach this based on risk.
“We do not have specific budget - we determine what is needed on a risk-based approach” “None of the above - budget allocation relates to business risk and/or business justification of opportunities to enhance compliance effectiveness and reduce hit on operational productivity”
Organisations were more confident in their ability to highlight where the overall compliance training spend is allocated - 12% of the budget is allocated to outsourced compliance programmes and this is expected to stay the same over the next two years. 16% of budget is currently allocated to delivery platforms and this is expected to stay the same and 25% is allocated to online content which is expected to increase. You will see from the table below that mature organisations are currently allocating 50% more of their budget to these two areas.
Table 1 Allocation of budget
% overall budget allocated across all sample
Mature organisations Changes expected in the next 2 years – by whole sample
Online Content 25% 39% Increase
3 The hopes and realities of technology-enabled compliance training
Organisations want compliance training to deliver significant results. Just look at the business goals –
organisations want to be able to manage risk more effectively, boost impact and create more engagement. Such high expectations reach nearly 100% across all of the top five business goals.
The reality tells a different story, however, with only 44% saying they are managing risk more successfully, 30% raising awareness and understanding of complex regulations and 23% creating uniformity and standardisation in work methods.
But there is hope. More mature organisations are reporting a different story, and it is one in which they are overcoming these challenges. More mature organisations are 40% more likely to raise awareness and
understanding of complex regulation, are 40% more likely to impact staff attitudes and values and increasing employee engagement and more than 30% more likely to positively influence behaviour and culture.
So what are the barriers to turning high hopes into successful learning programmes? Two out of three respondents say user engagement and half feel that line managers are a barrier to success.
Interestingly, only one in five say they lack credible design which may contribute to engagement, but more on that later!
Expectations are high
Organisations have high expectations for compliance training. They expect it to deliver business goals and not surprisingly expect to be able to manage risk more effectively as a result.
However, these high hopes are not turning into tangible results. Most compliance training is not achieving its business goals. In this section we explore what's working and what's not and identify the barriers to adoption. Expectations are high that compliance training will deliver business goals. Nine out of 10 respondents are looking for achievement across a broad range of goals, with those with a responsibility for compliance even more firmly focused on business alignment. The top 5 business goals cited are:
1. Managing risk more successfully (cited by 98% of respondents, rising to 100% of those with a compliance and risk management responsibility)
2. Impacting staff values & attitudes (98% - rising to 100%) 3. Increasing employee engagement (98% - rising to 100%) 4. Impacting staff behaviour (97% - rising to 100%)
5. Providing internal audit trail (97%)
Fewer were looking to reduce insurance liability or extend their learning to third parties, although expectations were still high in these areas:
• 87% looking to increase workplace transparency • 82% looking to extend learning to third parties • 75% looking to reduce insurance liability
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Most of these goals are being achieved – at least in part – as shown in Figure 4 below. The potential benefit for technology-enabled learning is clear, but the challenge is to consistently achieve these goals and close the gap between expectation and reality. Business goals that are not achieved, or are only achieved in part represent a considerable risk to the organisation.
Figure 4 Achievement of business goals
The total bar length indicates the proportion of the sample seeking each business goal. Red shading highlights those goals that are hardest to achieve.
Fewer consistently achieving goals
As you can see from the table below, there is a mismatch between what organisations would like to achieve and what actually happens on a consistent basis. Organisations are struggling with getting the outcomes they desire from compliance training. More mature organisations are having increased success at achieving their business goals but even they have some way to go to deliver on their ambition.
When it comes to managing risk, Table2 overleaf shows the gap the between the desired business goal and the percentage of organisations who are largely achieving that goal.
0% 20% 40% 60% 80% 100%
Protecting brand reputation Managing risk more successfully Positively impacting staff behaviour Postively impacting staff attitudes & values Raising awareness and understanding of complex regulations Creating uniformity and standardisation in work methods Changing working culture Reducing insurance liability Increasing workplace transparency Providing an audit trail for internal audit purposes Providing an audit trail for external auditors/regulators Increasing employee engagement through increasing awareness
Table 2 Achievement of business goals
Business Goal relating to managing risk % Desiring Business Goal All % Largely achieving Business Goal All % Largely achieving Business Goal More mature
Managing risk more successfully 91% 44% 54%
Raising awareness and understanding of
complex regulations 94% 30% 42%
Creating uniformity and standardisation in
work methods 91% 23% 25%
Protecting brand reputation 91% 59% 69%
The more mature organisations are 40% more likely than average to agree that they are consistently able to raise awareness and understanding of complex regulation.
At 59%, organisations are most successful at protecting brand reputation. However, this cannot be achieved without a change in culture, something that remains a challenge for most.
Some areas prove more difficult to achieve in full. Business goals relating to affecting a change in staff attitudes, behaviours or workplace culture appear to be the most elusive.
Table 3 Business goals relating to changing behaviour
Business Goal related to achieving behaviour % Desiring Business Goal All % Achieving Business Goal All % Achieving Business Goal More mature
Positively impacting staff behaviour 97% 26% 35%
Positively impacting staff attitudes & values 98% 23% 33%
Changing working culture 93% 12% 16%
Increasing workplace transparency 87% 16% 17%
Increasing employee engagement through increasing
awareness 98% 18% 26%
Behaviour change is proving to be a difficult nut to crack.
Culture remains the most elusive factor when it comes to compliance training. Nearly all respondents would like to change working culture as a result of a compliance training programme but very, very few actually achieve this goal.
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Figure 5 Changing behaviours
Barriers to adoption
Despite the ambition, effective compliance training is yet to become a reality for most organisations. So, what are the barriers to making this happen? As you can see from the top five barriers below, there are a number of challenges to be overcome.
Top 5 barriers – reported by half of all respondents or more: 1. 67% User engagement
2. 58% Staff reluctant to repeat year on year 3. 55% Dull and boring – previous bad experience 4. 50% SMEs overloading content
5. 49% lack of line manager engagement and support
The cost of setting up and maintaining a compliance training programme was also a barrier to 45% of respondents. Other barriers to success reported include:
“We are currently looking at an authoring tool that will allow us to do much more interactive learning. Unfortunately, our home-grown LMS does not allow access off-site, so our field staff struggle with
completing their requirements. I hope someday we will have an LMS and a way to pay staff that will allow learning from home and the field which will save costs and improve morale. We don't currently have consequences for learning not completed and that will likely show up in audits in the future.”
0% 20% 40% 60% 80% 100%
Positively impacting staff behaviour Postively impacting staff attitudes & values Changing working culture Increasing workplace transparency Increasing employee engagement through
increasing awareness
Largely achieving goal Business goal
Multinational organisations
For multinational organisations, translation into multiple languages, local data protection and employment law proved to be the biggest barriers.
They were significantly more likely to report barriers relating to:
• Translation into multiple languages (33% vs. 2% of those in single nations) • Local data protection or employment laws (23% vs. 9%)
“Employee engagement. A lot of our people know exactly what they have to do to be compliant and having them do training to prove it every year can be irritating for them.”
“Language barriers are a problem to compliance training. We are a diverse country, some people cannot relate well to English. And we have illiteracy problems.”
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4 The benefits of using technology to deliver compliance training
Having explored respondents’ expectations and how they feel they are performing against their goals, we asked how they quantify the benefits that have resulted from using learning technologies within their compliance training programs.
In this section we examine the perceived benefits of using learning technologies to deliver compliance training. We also take a look at what more mature organisations have achieved from using technology to deliver
compliance training.
The findings are stark: more mature organisations are more than two times as likely to change working culture and 75% more likely to report positive impact on staff behavior. The more mature are also more than twice as likely to report significant improvements in the cost of training delivery, reduced breaches or incidents and training time.
With experience of using learning technologies to deliver compliance training comes a range of business benefits.
Quantifying the benefits
In order to quantify the benefits we asked respondents aboutthe success they have measured, or know about, as a result of using learning technologies within their compliance training programmes. Given that this is tough to answer we presented a number of potential areas of improvement and respondents were invited to submit the improvements they recorded on a simple 4-point scale:
1. Over 15% improvement 2. Under 15% improvement
3. Some improvement – but we don’t know how much 4. No improvement
Although those recording over 15% improvement might have seen improvements of 20%, 30% or even more, in the subsequent analysis we used the most conservative baseline estimate of 15%:
1. Over 15% improvement (15% in the analysis) 2. Under 15% improvement (5% in the analysis)
3. Some improvement – but we don‘t know how much (0% in the analysis) 4. No improvement (0%)
Table 4 Improvements in efficiency and performance benefits
Benefits Average % improvement
Reduction in cost of delivery 9%
Maturity matters
Over the past ten years of research into effective learning practices, we have found that those who have
thoroughly embedded technology into all aspects of learning and development and are well aligned with the goals of the business, are achieving significantly higher results than most.
We have been tracking the extent to which the learning and development professionals are responding to and supporting business change and adapting learning to the needs of individuals and business. Those that are
achieving the best results are doing things differently from the rest.3 The Towards Maturity model described in the Appendix illustrates the good practice that characterises top learning companies.
In this study we wanted to investigate if maturity had the same impact in the field of compliance training and compared the benefits reported by those who were More Mature (established and embedded) versus the Less Mature (those reporting they are novice or sporadic users or are still in the process of developing their strategy). We found that the more mature are much more likely to be consistently achieving benefits related to risk. Figure 6 below highlights how the more mature are more likely to be largely achieving these benefits than the less mature.
Figure 6 The effect of maturity on the level of risk benefits achieved
0% 10% 20% 30% 40% 50% 60% 70% Protecting brand reputation Managing risk more successfully Raising awareness and understanding of complex regulations Creating uniformity and standardisation in work methods Less mature More mature
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More mature organisations are not only more likely to report that they are consistently achieving benefits relating to risk but also that they are consistently achieving benefits relating to behaviour change and working culture.
Figure 7 The effect of maturity on staff benefits achieved
More mature organisations are:
• more than 2x as likely to report changing working culture than those in the less mature category • 75% more likely to report positive impact on staff behaviour
Do those in compliance roles report different benefits than those in L&D?
Overall there were no significant differences between what the individuals in each of these roles were looking for from compliance training but there were a few areas where they perceived a difference in the benefits that they were largely achieving.
The table below shows that those managing compliance are more likely to believe that the working culture is shifting as a result of learning but are currently less convinced about audit trail benefits and insurance than their L&D colleagues.
Table 5 Comparison of benefits between those responsible for L&D and those in compliance job roles
Benefit achieved L&D only Compliance role Note Creating uniformity and standardisation in work methods 29% 17% L&D more
Changing working culture 10% 12% Compliance more
0% 5% 10% 15% 20% 25% 30% 35% 40% Positively impacting
staff behaviour Postively impacting staff attitudes &
values Changing working culture
Less mature More mature
1. Mature organisations report fewer barriers
Strikingly, more mature organisations have greatly reduced the barriers to adopting technology enabled
compliance training that are related to management support. There are a range of other barriers that also become less significant as organisations have become more experienced at using technology.
More mature organisations are:
• 31% less likely to report barrier of cost
• 46% less likely to report lack of design expertise
• 59% less likely to report lack of senior management understanding of risk • 74% less likely to report not a management priority
Less mature organisations struggle with making compliance a management priority, which comes as little surprise when 33% of them say that their senior managers do not sufficiently understand risk.
Figure 8 Barriers to compliance training
2. Mature organisations report greater quantifiable benefits
With maturity in using learning technologies in compliance training, comes marked improvement in quantifiable benefits. From reducing the cost of delivery and time spent on compliance training to significantly improved completion rates, organisations with more experience at using learning technologies are producing better results - and at less cost.
0% 20% 40% 60% 80% 100%
Cost of set up and maintenance Dull and boring - previous bad experience Subject matter experts overloading content Lack of subject matter expertise User engagement Lack of line manager engagement and support Lack of design expertise Lack of senior management understanding of risk Lack of credible design materials Not a management priority
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The figure below highlights that the more mature are over twice as likely to report more than 15% improvement in: • Delivery cost (more mature are 2.67x more likely to report over 15% improvement than the less mature) • Training time (2x)
• They are 1.6x as likely to report improved staff behaviour • 1.55x as likely to report improved completion rates
Figure 9 Percentage of sample seeing over 15% improvement in Key Performance Indicators
3. Mature organisations report better staff engagement
Staff in the more mature organisations are more engaged with compliance training and are less likely to need prompting to participate in it:
• 24% in more mature organisations report that staff engage with compliance training without prompting • Only 3% report this in less mature organisations
Having provided an overview of the impact of learning technologies in delivering compliance training, the second half of our report will investigate how organisations are approaching compliance training.
0% 10% 20% 30% 40% 50% 60%
We have decreased cost of delivery We have improved compliance completion rates We have decreased time spent on compliance
training
We have improved employee understanding of compliance policies and proceedures We have improved rates of adherence to policies
and procedures
We have improved staff behaviours
5 Thinking differently about methods /media/blends
Although face-to-face delivery remains a popular choice for compliance training, 46% of organisations prefer to use online delivery only. By looking at more mature organisations we can see the increasingly important role of learning technologies in delivering compliance training and within this we can see more focus on blends and different uses of a variety of platforms.
E-learning courses remain the staple for online compliance training for most organisations (81%) but
collaborative platforms such as SharePoint and in-house social media are starting to become an important part of the mix, for 69% and 50% of organisations respectively.
Mobile learning is also starting to feature with 33% of organisations using mobile devices to access compliance content and 25% using mobile apps. Organisations expect to significantly increase the use of mobile in the next two years – 56% for accessing content and 46% developing apps.
Comparing more mature organisations with the less mature, we see that they are 177% more likely to use apps, 158% more likely to use virtual classrooms and 157% more likely to use a dedicated online portal for compliance content.
More mature organisations are also twice as likely to consider storytelling, performance support and to provide resources for managers when designing compliance training. Telling compelling stories and enabling audience participation are becoming key ingredients to successful technology-enabled compliance training.
What learning methods are currently being used in compliance training?
A range of different techniques are used to engage staff in compliance training. Much of this is via a face-to-face route in classroom-based training, but an increasing amount is moving online, or to be supported by learning technologies.
• 41% of all current compliance training is delivered face-to-face • 19% through a blend of learning methods
• 46% using learning technologies only
These proportions vary somewhat with maturity, with the more mature organisations more likely to use learning technologies either on their own, or in the mix of methods.
Self-study lessons are widely used (in 87% of organisations and supported by technology in 73%), with webinars used in 66% of organisations for compliance training.
“In the future, we intend to integrate online learning more into risk-based training. Currently, most is done by face to face training efforts, then cascaded.”
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Figure 10 Learning methods supported by technology
In the future, organisations are predicting a marked shift away from face-to-face training towards more learning technologies. That said, the trend to use more learning technologies is less noticeable in more mature organisations in which there is already a higher proportion of training e-enabled:
“We are currently reviewing our online learning and would like to make appropriate use of more technology (on-line
assessments, hand held devices, Apps etc...)”
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Coaching Action planning Role play Communities of practice Check lists and job aids Self study lessons Games/simulations Assignments Reading Instructor/facilitator led workshops Manager-led/team meetings Diagnostics Webinars
Using learning technologies Offered
Most likely to be delivered • Face to face o Team meetings o Instructor workshops o Coaching • Blended o Checklists o Reading o Assignments
• Learning Technologies only o Self study (51%) o Webinars (44%) o Reading (36%)
Award-winning multi-stranded anti-bribery learning programme
Leading wireless technology supplier CSR partnered with SAI Global to create and deliver an award-winning anti-bribery and corruption (ABC) learning programme designed to embed, communicate and reinforce a zero tolerance stance on bribery and corruption across CSR’s worldwide locations at all levels of the business. The ABC programme was part of the company’s response to the UK Bribery Act 2010 (UKBA), which stipulates ‘proportionate’ training and communication as one of its 6 principles for adequate ABC procedures.
A clear objective of the training was to enable all employees to understand the impact of the incoming legislation for CSR and for them as individuals. This was achieved by providing thought-provoking, reflective content that was not only relevant to CSR as a business, but also relevant to employees’ daily job roles. ‘Based on our audit, we fully understood the risk-profile of CSR’, explained Ian Purdie, Learning &
Development Manager at CSR. ‘We knew exactly how many people we had in what sort of roles and in which locations, and we discussed how our training and education could achieve the necessary positive impact – not just now but on an ongoing basis’.
CSR elected to combine three different strands of learning – online learning for all employees, facilitated workshops for managers and employees in high risk functions or regions, and a trainer programme designed to create a cohort of people around the world who would be able to deliver the facilitated workshops for future initiatives.
SAI Global’s online learning programme ‘Preventing Bribery and Corruption’ was customised for CSR to incorporate images, graphics and terminology that would immediately resonate with employees. Additional scenarios or ‘lessons’ were developed to help employees spot potential red flags in situations that they could relate to. The course also enabled learners to be ‘profiled’ prior to starting the programme so that the content and lessons they received were relevant to their job roles.
‘The need for online learning surfaced very quickly during our discussions’, said Ian Purdie, ‘however it was widely recognised that this would have to be high quality online material. It needed to be targeted and it needed to be tailored. This meant that the particular message employees received was relevant to them so they would have the confidence and knowledge to conduct themselves entirely in line with the requirements of the legislation’.
An impact survey circulated throughout the learner population post implementation revealed that the learning programme had successfully delivered on learning and business objectives and had had a significant positive impact on employees’ knowledge of and attitudes and behaviour towards bribery and corruption.
You can read the full case study here. http://www.saiglobal.com/compliance/about/clients/case-studies/cambridge-silicon-radio.htm
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Technology/media in use
Of all the technology solutions available to organisations, the self-paced e-learning course is the preferred choice for delivering compliance training. This is set to continue for at least the next two years. Video conferencing and webinars are also widely used, as are internal collaboration platforms such as SharePoint.
Both internal and external collaboration platforms are set to be used more according to respondents. Online performance support tools and video content will also be used more widely.
The technologies in use by the most organisations are:
1. 81% use e-learning courses – created in-house 2. 73% use webinars and video conferencing 3. 69% have a dedicated online portal
4. 69% use internal/enterprise-wide information services such as SharePoint 5. 62% use e-learning courses – custom-made sourced externally
6. 61% use e-learning courses – ‘off-the-shelf’ sourced externally
The use of social media technologies in compliance training is still low – at 28% for external third party sites such as Facebook, LinkedIn and Twitter. These sites are becoming increasing important in the more general L&D artillery, in use in 45% of the 500 participants in 2012. Some growth is predicted in the compliance field over the next 2 years with this figure set to rise to 37%.
In-house social media networks are more important (50% using now), particularly in large and multinational organisations and are predicted to increase in use to 61% in 2 years’ time.
Multinational organisations
Multinational organisations are more likely to be using the following technologies than those in single nations: • In-house social media (60% vs. 35%% of those in single nations)
• Virtual classrooms (46% vs. 26%) • Podcasts (46% vs. 34%)
They are less likely to be using:
• External social networking sites (25% vs. 34% in single nations) • ‘Off-the-shelf’ e-learning (56% vs. 69%)
Organisation size is a key issue here, with these differences exaggerated in larger organisations (over 15,000 staff) irrespective of whether they operate multi-nationally or not:
• In-house social media (74%) • Virtual classrooms (57%) • Podcasts (59%)
In-house created e-learning is the most popular form of technology-enabled compliance training (used by 81% of organisations) and this is set to grow to 87% in the next two years.
This compares with custom-made, externally sourced learning courses which are currently used by 62% of organisations. Again, this is set to grow with 72% of organisations expecting to use them in two years' time. Online performance support tools are being used by 48% of organisations and this is set to increase to 61% in the coming two years. Respondents anticipate a 15% increase in the use of video for the same period.
Dedicated online portals, currently used by 69% of organisations will be used by 79% of organisations in two years' time.
Few respondents are predicting that they will actually decrease the use of certain tools in the future, but we do see the largest numbers reported in:
• Video content – user generated stories (14% report they will decrease use) • Online performance support tools (14%)
• E-learning courses – custom-made externally (9%)
“Since much of the compliance need is information awareness we're not going to invest much to make the courses more entertaining, animated, graphical, etc. We'll stay with narrated e-learning.”
“My feeling is that it is the off the shelf compliance/regulatory training that gives this type of training a bad name. My experience of off the shelf training is that the majority of it is dull and usually filled with too much irrelevant information, due to the fact that the author doesn't know what audience they are writing for, so they have to cover all eventualities. They also tend to fill training with irrelevant gimmicks to make it seem more interesting.”
What delivery platforms and tools are being used to support compliance learning?
Although the LMS is currently at the heart of online compliance training – and is set to become a major part of online delivery in the coming years, the biggest leap in technology use will be in the use of mobile, jumping from 25% usage now to an expected 46% usage in two years’ time.
Table 6 Delivery platforms
Using now Will be using in 2 years
Learning management systems (integrated with HR or standalone) 83% 91%
Online assessment tools 77% 84%
Diagnostic tools 38% 49%
Mobile devices to access content/courses 33% 56%
Mobile apps 25% 46%
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What does good look like?
So what are more mature organisations doing to make their online compliance training more effective? Providing staff the opportunity to interact with content and to access it at the point of need (online performance support tools) are key ingredients.
More mature organisations are also designing experiences that tell a story in an imaginative way and that enable staff to actively participate in the learning materials. Dedicated portals and virtual classrooms are also more popular. And the more mature are almost twice as more likely to be using mobile platforms now to support compliance.
The more mature organisations are more likely to use the following technologies to deliver compliance training:
Table 7 Technologies used by mature organisations
Less
mature More mature
Online assessment tools 75% 81%
Webinar/Video conferencing 70% 77%
Online performance support tools 45% 51%
e-learning courses - created in-house 76% 88%
Internal/Enterprise-wide information services such as SharePoint 65% 76%
In-house social media 45% 56%
e-learning courses - custom-made sourced externally 56% 73%
Illustrations/animations 52% 69%
Other online resources eg eBooks, eJournals 53% 72%
Diagnostic tools 33% 47%
Dedicated online portal 56% 88%
Virtual classroom 31% 49%
Technologies where usage actually decreases with maturity include:
• Off-the-shelf e-learning 53% of mature organisations vs. 67% less mature • Podcasts (38% vs. 42%)
• Third party social media (26% vs. 31%)
When it comes to design, only one in five organisations include opportunities for staff to practise while two in five organisations use storytelling to make the content more engaging. Only one in five organisations provide managers
More mature organisations are far more likely to use storytelling to bring learning alive (59% vs. 29% for less mature organisations) and are twice as likely to use visuals and animations to create more engaging content.
“Prior to undertaking any implementation/design/redesign of any compliance content, I would strongly recommend undertaking the Towards Maturity Learner Survey. Without the critical data that it provides, you could well be missing an important perspective - your learners'!”
Code of Conduct Training – A Long Term Strategy for Pharmaceutical Companies
In 2008 a newly formed Global Compliance Team was given the task to establish, drive and embed a culture of ethics and integrity at a leading Pharmaceuticals company. A key objective was to improve compliance
behaviours through effective training and support.
A new Code of Conduct was implemented, providing the framework for consistent policy standards for all employees. For the first time the whole organisation would be held accountable, globally and
cross-functionally, against one Code of Conduct. As a result, the company needed to develop and deliver Code of Conduct awareness training to 65,000 employees worldwide.
After conducting a rigorous benchmarking process to provide insights into what kind of solution and format they should use for training, the company decided to use e-learning as the key delivery method. They chose to partner with SAI Global to develop and deliver a bespoke e-learning solution.
The e-learning was developed with input of over 125 stakeholders worldwide from different parts of the business. Project management was therefore an essential element of the planning, development and delivery. Both SAI Global and the client employed dedicated project managers to keep the project on track and to identify and resolve potential issues throughout the project.
The instructional design process played a key part in identifying and overcoming potential content issues. It was essential that the design of the programme was based on clearly defined learning objectives. The programme also needed to take into account adult learning theory, appeal to different learning styles and cultural differences. By adopting a modular and scenario-driven approach, many of these issues were overcome. Profiling was also used to create stranding of content for each learner, to ensure that the training was appropriate and relevant to each job role at the company.
SAI Global developed a compliance e-learning programme that would reinforce the organisation’s long term vision for imbedding ethics and integrity in to the workforce. The training was split into three key elements that would span a three-year delivery programme. Each year the training would build on employees’
knowledge from the previous year, and help to enhance behaviours and attitudes towards the Company Code of Conduct.
Implementation was hugely successful and results demonstrate that end-users are getting real value from the programme. Read the full case study here: http://www.saiglobal.com/compliance/about/clients/case-studies/code-of-conduct-training.htm
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6 Thinking differently about your audience
In this section we examine what the data tells us about how organisations are delivering content for specific audiences. The findings show that different job roles require different approaches, something that is critical to the design of engaging compliance content.
Our data shows marked differences in how people in high-risk roles, managerial roles and general roles would like to access compliance content. Managers are more likely to prefer webinars (40%), high risk roles more likely to prefer in house developed content (38%), as are those in more general roles (62%). We also provide a
broader, international perspective that is quite revealing.
The UK has a lot to learn from the rest of the world. For example, only 31% of UK organisations ensure compliance training is role specific compared with 65% (rest of world).
In the UK, more matureorganisations are 40% more likely to agree that compliance training is role specific.
Role specific
Organisations are beginning to tailor their compliance content to specific job roles, with 38% creating role specific compliance learning. But who in the organisation is receiving this more personalised content?
The answer is those in high risk job functions - 51% of organisations target their training content for this group according to their role. When rolling out programmes across all employees, 3 out of 5 offer the same content to everyone and do not vary this with job role.
Figure 11 Targeting content according to job role
0% 10% 20% 30% 40% 50% 60% 70%
Same content Content targetted to role
All company High risk jobs
Who is most likely to personalise content for those in high risk job functions?
Above average of 51%:
• 71% Large companies (>15000 staff) • 59% More mature companies • 54% Those in risk management roles • 52% Multinational companies Below average:
• 49% Companies operating in a single nation • 47% Small companies (<2000 staff)
• 46% Less mature companies
Preferences for delivery media
Looking more generally at user preferences, we asked which delivery media are most used/preferred by different audiences. Note that this is the perspective of the L&D professional on their learner’s preferences but even so provides interesting comparisons. Our data shows that there are significant differences in what type of content different audiences prefer. One size does not fit all.
Table 8 User preferences for delivery methods
Technology High risk roles Management roles General roles
e-learning courses (external) 25% 29% 44%
e-learning courses (in-house) 38% 33% 62%
Webinar 24% 40% 39%
Serious games/simulations 6% 10% 19%
Social networks 4% 7% 32%
Mobile 7% 13% 18%
The participants believe that those in high risk job functions are less likely to note preferences for any listed learning technologies than those in management or general roles.
Those in high-risk job functions are more likely to prefer to use e-learning courses and content rather than more informal delivery media. For those in management, there is a preference for webinars and video conferencing. When it comes to technology, managers are more likely to prefer webinars, general and high risk roles are more likely to prefer in house developed content. General roles are more likely than others to prefer collaborative social network environments.
What does good look like?
Creating and adapting content for specific users and delivering it via their preferred technology will bring more success for compliance programmes. More mature organisations are 20% more likely than the less mature to agree that learning is adapted to role and 40% more likely to agree that compliance training is role specific.
More mature organisations are more likely to be using custom-made e-learning content that is tailored to the audience – for example, 73% use externally created e-learning (vs. 56% of less mature organisations) and 88% create their own content in-house (vs. 76%). They are also 40% more likely to use diagnostic tools to help match learning to individual requirement.
It is interesting to note that when it comes to role specific training, the UK has a lot to learn from other countries. In the UK, 44% of organisations ensure that compliance learning is role specific (versus 65% for the rest of the world) and 33% ensure that the learning is adapted to role (versus 43% for the rest of the world).
“Some e-learning products are created on a national basis for rollout. These do not always recognise local position or learner need. The learner knows instantly if a product has been designed with them in mind or is a generic 'one size WILL fit all' product, that in itself can be a turnoff.”
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7 What does good look like? Aspects of implementation
Our data shows that learning and development professionals would do well to look at how compliance
professionals approach compliance training. For example, only 29% of L&D professionals send reminder emails to encourage employees to apply their learning back in the workplace. This compares with 61% of compliance managers.
Communication is just one element that makes for effective implementation. The mature organisations also know how to align their compliance training to business goals. They know how to engage all stakeholders and they know how to deliver the right content for the right people.
They also know how to demonstrate the value of learning. Interestingly, respondents say they have high hopes for compliance training but the reality is they are loath to demonstrate the value that compliance training can bring. In less mature organisations, only 3% of L&D professionals collect success stories and share them. Overall we find that:
• 55% ensure that business process and learning outcomes are aligned.
• 36% agree on average ensure there is a communication plan in place for all key stakeholders • 27% agree that managers encourage and make time for staff to study on the job
• 16% collect information from learners on the extent to which they have applied their learning –
interesting given the numbers looking to change behaviour and values
Mature organisations are 40% more likely to think about business problem before recommending a solution, and ensure business process and outcomes are aligned.
They are also at least twice as likely to implement internal marketing campaigns and ensure a stakeholder engagement plan is in place. Communication around compliance training is critical to success.
Alignment
Despite the ambition for compliance training to deliver significant business impact, we find in many cases that compliance training is still not fully aligned to business goals. With only 55% ensuring that business process and learning outcomes are aligned, there is clearly a lot of room for improvement.
On average:
• 60% of organisations are aligning learning to performance objectives • 65% analyse the business problem before recommending a solution • 55% ensure that business process and learning outcomes are aligned
• 79% understand the regulator's requirements for compliance training, where appropriate • 60% align learning to performance objectives
“We will continue to ensure that our compliance training matches the business need and use a variety of methods to ensure we are not missing any areas.”
Those with responsibility for L&D are less likely to ensure their provision is closely aligned to business need than those in compliance roles: those in compliance are more likely to be analysing the business problem than their L&D counterparts (70% vs. 58%)
Table 9 Alignment to business goals
L&D roles Compliance
roles
We analyse the business problem before recommending a solution 58% 70% We ensure that business process and learning outcomes are aligned 52% 58% Where appropriate, we understand the regulator's requirements for compliance
training 82% 74%
We align learning to performance objectives 56% 61%
Engagement
In the design phase, more mature organisations work with subject matter experts to create content and include users more in the design process.
On average 58% of organisations strongly agree that their subject matter experts work in conjunction with learning professionals, 33% say that managers and users are involved in the design process.
Table 10 Engagement with stakeholders
Less mature More mature
Subject matter experts work in conjunction with learning professionals 54% 64% We include managers/users in the design process for the programme 31% 36%
Those in multinational organisations are less likely to include managers and users in the design process
• 26% of multinationals agree that they include managers/users in the design process for the programme (vs. 40% of national organisations and 33% sample average)
In the 2012 benchmark:
• Only 17% involve managers in the design of the most appropriate solution – only 10% in the public sector – rising to
• 46% in top learning companies (those in the top quartile for TMI – see Appendix for details)
“Challenge the subject matter experts on what REALLY needs to be in the course as they like to include everything to cover all of the bases, whether the end user needs to know it or not!”
“Subject Matter Experts can be difficult to change mind sets. SMEs are also sometimes dealing with the learning as a hobby with no actual line manager support. Ownership of content does not sit with L&D but the business.”
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Communication
As we saw earlier in the report, less mature organisations are hampered by lack of manager and senior manager buy-in. Communication is essential at all levels – from those at the highest board level in the organisation to the end users, the learners, to engage and motivate them. Our data tells us that:
• 36% agree on average that they ensure there is a communication plan in place for all key stakeholders (compared with 40% in the 2012 benchmark)
• 61% work with directors and senior managers to endorse learning (21% in the 2012 benchmark agreed that ‘Our top managers are involved in promoting technology enabled learning’)
• 25% work with local champions (36% in the 2012 benchmark) • 42% implement an internal marketing campaign
• 27% agree that managers encourage and make time for staff to study on the job (23% in 2012 benchmark) • 8% collect individual success stories and communicate them back to users (compare with 27% in the 2012
benchmark who ‘publicise the successes of individuals as a result of learning technologies’) Mature organisations are more likely to be communicating in all these ways.
Across the whole 2012 benchmark, we found that 2 out of 5 organisations ensure there was a communication plan for all key stakeholders. This falls to 36% in this study and just 22% of less mature organisations.
Local champions are equally likely to be found in the big multinational organisations and the smaller, national companies. However, there are large differences between the approach of those in compliance roles and those in L&D alone.
What we see here is the emergence of a carrot and stick approach. More mature organisations are much more likely to send out regular reminders, internally market their learning – but also are more likely to discipline staff for non-completion.
“Changing attitudes and enthusiasms is like many business processes 'a top down thing' and unless management teams 'buy in' it is a very difficult trick to pull off successfully.”
“We use a network access system that can block access if compliance is not confirmed/completed”
Demonstrating the value of learning
Despite the high hopes that come with compliance training programmes – as outlined earlier in the report – L&D professionals are missing opportunities to demonstrate the value of their compliance programmes.
Across the whole study we found that on average:
• 8% collect individual success stories and communicate them to users • 43% report progress against KPIs for business
Again there are significant differences between those with different areas of responsibility and levels of maturity as shown in Table 11 overleaf.
Table 11 Demonstrating value
Less
mature More mature
We collect individual success stories and communicate them to users 3% 16% We report progress against key performance indicators for learning 25% 46% We report progress against key performance indicators for business 36% 55% We collect information from learners on the extent to which they have applied
the learning 12% 24%
“Our success rates are directly linked to the involvement of the internal subject experts from the earliest learning design stages. Attractive e-adverts with hyperlinks to learning content have improved completion rates.”
The most important aspect of any training is that the learner understands why it is relevant and important to them - if it is not or they do not realise that it is, they fail to engage and often fail to learn.
Special consideration for multinational audiences?
Implementing compliance programmes across many countries is not without its challenges, but multinationals are more likely than their single country counterparts to design engaging content, get senior management buy-in and encourage application in the workplace.
Table 12 Implementation for multinational organisations
Bold indicates multinationals are at least twice as likely to agree with the statement as those in single nations.
Percentage agreeing with each statement Single nation Multi-national
We provide managers with resources and job aids to encourage application back in
the workplace 14% 29%
We discipline staff for non completion of mandated compliance learning 12% 36% Our staff engage with compliance related training without prompting 5% 16%
We use storytelling to bring learning alive 29% 49%
We work with directors/senior managers to endorse learning 55% 67% We collect information from learners on the extent to which they have applied the
learning 14% 18%
We collect individual success stories and communicate them to users 7% 9% We include managers/users in the design process for the programme 41% 26%
We ensure that compliance learning is role specific 38% 48%
We use visuals and animations to create content that is engaging and interactive 38% 47%
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That said, cost and local laws are barriers for multinationals. They are much more likely to report barriers relating to:
• Translation of learning into different languages (reported by 33% vs. 2% of those in single nation) • Cost of set-up (52% vs. 36%)
• Local data protection and employment laws (23% vs. 9%) Tips from multinationals:
“Understand. Get an early grasp on your translations approach (which languages for which audiences - internal/external) - and why.”
“Keep the learning outcomes consistent with local adaptations to use with differing policies and procedures. We are not looking for total uniformity.”
“We are engaged in a demanding and complex preparation for the roll-out of the anti-corruption e-learning program in four countries due to the local adaptation in legal issues and ensuring the policy alignment and the compliance culture conformity.”
And several considerations shared by one multinational participant:
“Data protection -> respect the local law and get commitment
Different platforms -> create e-learning adaptable for different platform solutions (including SCORM-versions)
Overcome cultural differences by changing content and using local pictures or situations
Increase the number of participants on e-learning programmes -> again a cultural issue; some countries need more than 10 reminders per participant, depending strongly on management commitment to compliance training.”
