When evaluating compliance training, here are four questions to ask:

Is the training relevant to your employees and managers? Can it be customized to your organization's industry, culture, brand and internal policies and procedures?
Is the training up to date? Not only is it critical that training is current with your organization's policies, practices and new laws and regulations, content needs to stay fresh so employees aren't taking the same course year after year.
Is the training behavior-based? Rather than focus on avoiding liability, effective training should focus on changing behaviors, raising awareness of what is and isn't appropriate workplace behavior and the consequences of misconduct.
Does the training keep learners engaged with relevant examples, interactive scenarios, and practical actions that they can put into practice immediately?

When evaluating compliance programs overall, again, organizations should refer to the key components of the DOJ's guidance, such as:

Have there been significant investments in, and improvements to, the corporate compliance program and internal controls systems?
Have the remedial improvements to the compliance program been tested to demonstrate that they would prevent misconduct in the future?
Have policies and procedures been integrated into the organization, including through periodic training?
Are there reporting mechanisms in place for employees to anonymously or confidentially report allegations of a breach of the company's code of conduct or other misconduct?

In 2022, we can expect employees to continue to look to leadership for clear guidance, reassurance, and support in a time of uncertainty. Creating a strong foundation of ethics and compliance can help build trust, encourage honest feedback, and empower employees to bring their whole selves to work and make the right decisions that reflect the organization's values and culture.

Instant Insights /

Ethics and compliance training in 2022: A Q&A with John Arendes

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