Know your audience
One of the most important elements of an effective compliance program is employee training. In-person training is critical to achieving full comprehension of compliance policies. When training is presented in an in-person format, it allows employees to ask questions, express frustration and challenge the presenter to listen and work together to overcome real or perceived obstacles that may be preventing full compliance to corporate policies.
Rather than reading from slides and dictating in an hour session what is allowed and what is not allowed, we are convinced that getting the message across to your audience requires improvising, sharing real life experiences and at times some humor. The presenter’s body language and tone when speaking is a powerful tool in getting the message across.
A great and much appreciated challenge was provided to STEER when we were given an opportunity to conduct in-person employee training for a client where some of the employees were visually and/or aurally challenged.
To accommodate the attendees, our training slides were converted to braille, and sign language interpreters were present during the training (as well as a number of beautiful and well behaved guide dogs).
I realized that my training required me to improvise, as my body language and tone of my voice would not have the same effect on attendees I had spoken to on many other occasions. I usually conduct trainings using only a few power point slides. I thought that perhaps for these sessions, I should stick to what the slides contained and not deviate from what had been converted to braille? After reflection, I decided that these training classes should be presented as usual, and that the real life stories, which were not on slides, were an important part of the overall training experience for the attendees.
For those individuals in the audience who were aurally challenged, the sign language interpreter could present the stories in sign language, and all I really needed to do was not to speak too fast to allow the interpreters to be able to interpret properly.
But what about someone who was both blind and deaf and would only be able to follow material that had been converted to braille. For those presentations it seemed like a good solution would be to choose certain supportive stories in advance and have them converted to braille and inserted when needed during the training presentations.
Although I am a seasoned presenter, I must admit that I was nervous before I started the various training sessions. I wanted to ensure that for all who attended the training, it would be effective and appreciated. The client was highly appreciative of the way STEER had conducted the training.
Compliance training can be rather dry if presented as a review of company policies only. It takes human interaction and energy to make it successful. The take away here is to know your audience before preparing for the training.
Meeting CEO Mahatma Gandhi
The trip was never ending – the flight to Mumbai followed by a five hour ride on a bumpy road to finally arrive in this little town in the middle of nowhere - but we made it and after a refreshing shower, I was ready to visit the factory and meet with local management to discuss our business plan.
We started with a factory tour and the plant manager proudly presented his workshop, nicely decorated with flowers.
“Well, it is rather seldom that guests from the European Headquarters make this long and cumbersome trip to visit us here, so the flowers are especially for you”, the plant manager commented.
I appreciated the gesture and felt honored. However, what really attracted my attention was the many pictures of Mahatma Gandhi posted all over the walls in the workshop. And even more, I was wondering what the handwritten text bubbles, added above Mahatma Gandhi’s face, was all about.
It looked as if a “comic book version of Gandhi” had something to say. I did not understand the words written in local language, so I asked the plant manager to translate. “Keep all client information confidential”. “Do not bribe”, “Treat your colleagues with respect”, were a few of the statements made in the text bubbles.
I had never guessed that Gandhi would make these statements. “No, I don’t think so either” was the response from the plant manager, “but you know, the European Headquarters is so far away and my people have never seen anything else but their village and this factory. In fact, they probably don’t even know the name of our CEO. But they know who Mahatma Gandhi is, and Gandhi’s words are strong and holy”. “So, in order to deliver the message from the European Headquarters, I am “using” Gandhi to deliver the message of our company’s Code of Conduct. I hope this is compliant?”
This manager found an effective way to communicate a global message from HQ in local language to a local audience, understanding their culture.
Thanks, but No Thanks
We were investigating an allegation that import duties of a country were deliberately avoided through an illegal scheme, whereby products manufactured in another country were valued at a much lower cost than the actual value.
During our investigation it was established that a local sales manager had managed to negotiate discounts up to 70% on products bought from company owned factories abroad.
By selling these products for several years, with a 25% mark up to third party companies in his region, he became a high potential employee and received multiple recognitions for his consistent contribution to the local company’s profits.
A review of this successful sales manager’s personnel file revealed that he had refused multiple offers for a promotion into a more senior sales position. Although, there are many legitimate reasons why someone does not accept a promotion, this is a red flag, which requires further review.
It was established that a promotion of the sales manager would require him to move to another location, where he would be responsible for a different client base than in his current position.
A review of his customers established that he was intimately involved in the business dealings with one specific local customer, who bought the above mentioned products from the sales manager at the 25% mark up, and resold them to third parties with an additional 50% mark up.
A further review established that the local sales manager had an ownership interest in the local customer and that the 50% mark up was split between the sales manager and the customer. As such the sales manager’s income from these inappropriate and illegal actions far exceeded his salary income.
The scheme had been in place for years. Since the company results showed a 25% profit on products sold, no red flags were identified initially.
The fact that the sales manager refused a promotion including related salary increases several times, was a red flag, which should have been detected by the company at an earlier stage.