Continuing education and training is integral to an organization's ethics program. I always launch my company's CE program in the summer in between the annual audit cycles (anti-money laundering audit has just ended and annual controls audit will commence in the fall). As a former teacher, I understand the importance of tailoring courses to different audiences and the value of effective pre- and post analysis. A needs assessment is the crux of an effective CE program and should consider the following aspects prior to executing the curriculum:
1. Previous findings on audits or regulatory exams: Careful review of all outside auditor reports and examination findings should be addressed immediately throughout the organization (or department if very specific) in the form of training and education. Since audits are designed to find systemic issues, education is key to communicate why an issue occurred and to educate employees on how the process is changing and why.
2. Change in business lines: I work at a very entrepreneurial company where ideas are incubated constantly. Culturally, this spirit is exciting. However, this means that different controls, ethical considerations, and regulations are constantly in flux. All new business lines being launched should be considered to ensure staff are being trained on relevant regulations, system controls are being implemented and the ethical considerations this new activity raises (i.e. conflicts of interest, supply chain, employee rights). For example, if your company is launching an app or will be offering data analysis, client data confidentiality will be important and new for some employees. Controls and regulations are important, but an organization should train its employees on why it matters ethically to keep client data secure and confidential.
3. Collaborate: Speak with department managers and human resources on trends or needs they see within their projects or teams. Note any feedback on topics they would like their team to be trained on.
4. Internal discipline and enhanced supervision: Work with human resources to offer additional training to employees who have been disciplined. Of course, these employees and the reasons for discipline may be confidential depending on your role, but designing the CE training modules or refresher courses can be completed for types of disciplinary actions with the help of HR, and can be assigned confidentially and by the appropriate person later.
5. Research industry trends: Is there negative or positive news about a peer company or in your industry that addresses ethical challenges or accomplishments that should be emulated? Collaborate with Compliance, Legal, Operations to ascertain new ideas that should be incorporated into continuing education modules.
6. Cultural shifts within the organization: If company executives are launching a new CSR or sustainability program, the initiatives should be communicated to ALL employees, not those whose daily roles are directly effected. These initiatives will impact the entire organization and continuing education is an excellent way to train employees and divulge new initiatives in a positive, organized way. Communicating positive initiatives to everyone also creates more buy-in from all employees, which should have been one of the considerations when implementing this program in the first place. Work with department heads to tailor CE modules to their teams so the information is relevant to them whilst expressing the thesis for the initiative and how it will achieve the company's overall mission and demonstrate its values.