Many compliance officers proudly use the number of people that have been trained as evidence of the success of their programmes or systems. But getting 90% or even 100% of people to attend a training session doesn’t really help you or management assess the contribution that a programme is having to your overall risk profile, nor does it show how the programme is performing against its objectives (assuming those objectives are more than just ‘100% trained’).
This focus on training and its reporting as a percentage of completion is simplistic and falls significantly short of modern-day compliance measuring expectations. Programmes that measure success in terms of percentage of people trained should reconsider how they report out on their objectives, and even question what those objectives are.
When considering how training aligns with the goals, objectives and measuring of any of your ESG initiatives, we at Speeki have five important tips.
- The fact that people are being trained is valuable, but it is not an indication that risk is being reduced – that is like saying that there should be no more car accidents because everyone driving a car has been trained on how to drive. Just like driving a car, while repeated and ongoing training is an excellent tool, the actual training itself is unlikely to have a significant impact on the reduction of issues. If you could measure the impact that the training had on risk reduction, that would be a more valid statistic. Achieving 100% of people completing a short e-learning course is hardly cause for celebration; however, reducing a risk from recurring through those training efforts is.
- It is good practice to test the effectiveness of training. This can be done by testing, assessments, knowledge recalls or feedback loops. Testing the effectiveness is essential to know whether the training actually worked, if there was value in the content and whether the content was absorbed by the participant. Training should not be confused with awareness; awareness is focused on making someone aware of an issue so that they stop and think, and training is focused on achieving a repeated ‘muscle memory’ of how to do a particular task. Of course, if your training is just a 15-minute e-learning module on general ethics, for example, the best you can hope for in terms of effectiveness is the trainees recalling that they did the training and remembering the company’s high-level stance on a particular issue. You can’t expect much from content that is too general and high level and meant for mass awareness.
- Linking the measurement of the training exercise to a particular risk objective is also good practice. An example might be a communication stating ‘As part of our anti-corruption controls, we have seen more people requesting gifts incorrectly, so we are going to do some specific training around gifts, procedures, policy and how to understand our principles around gifts.’ After the training you could then measure whether there was a decrease in the number of gift approvals being requested that fell short of the standards. Measuring the before and after will go a long way towards determining whether the provided training had any actual impact on the issue that you were trying to address, and therefore help you quantify whether the training helped you achieve the risk objective.
- To take that one step further, you need to show the impact of the risk reduction in business terms. Businesses measure success based on revenue growth, cost savings, customer satisfaction and reputation. Management want to know whether their investment in the programme is providing value. It is not always about the result of your programme (e.g. no bribery, no safety issues, no environmental disasters, no fines), but rather the performance of the programme that you have built and designed to manage that risk. In each of your reporting results, think about the impact to the business in business terms. Using the example from tip four, how much time will be saved if less people submit incorrect gift applications? How much less money will be spent sorting out issues that occur as a result of incorrect approvals? Remember that, in business, time is money and is therefore a valid measurement of cost and success.
- Finally, think about the way to present the information to management. Information from a point in time is hard to relate to. For greater impact and understanding, use a simple chart showing trends over time so that the reviewer can see how things are performing now compared to how they have historically performed.
There is no doubt that training is a necessary tool in a modern ESG programme. But it is exactly that: a tool to help you achieve your objectives, not an objective itself. Success must be measured in how effective the system is at managing risk.
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