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James A. Nortz
CARES TREAM HEALTH
I have a confession to make: When I buy a
gizmo that’s labeled “some assembly required,” I
dump the parts on the ground and go at it with a
wrench and screwdriver — figuring that reading
the directions will only slow me down. Typically,
I only resort to the directions if the finished
product doesn’t look like the picture on the box.
Given my aversion to assembly instructions,
I sympathize with employees who choose to do
their jobs without looking at company policies
and procedures. Like me, most normal people
only look at corporate governance documents
when compelled to do so after all other options
have been exhausted.
Unfortunately, the consequences of not knowing
the rules at work are far more dire than the poorly
assembled items that I construct to “save time.”
As we corporate counsel know all too well, such
ignorance can lead to shattered careers, workplace
injuries, scandal, damaged reputations, civil and
criminal liability, and a whole host of other adverse outcomes that can be tragic for all involved.
This is one of the many reasons why training
programs designed to help employees understand
and follow the rules are one of the cornerstones of
effective enterprise risk management.
The problem, of course, is that no one likes to
deliver or sit through such training programs.
More often than not, they are check-the-box
exercises that have little impact on employee
behavior. If you are tasked with helping your colleagues understand and follow company policies,
the following three guiding principles may help
improve your chances of success.
1. Aim for a “level three” understanding
In my first year of law school, my professor
explained there are three levels associated with
understanding any rule:
■ ■ Level one: Understanding is achieved when a
person knows there is a rule. They don’t know
what it says, but they know it’s there. This is
not ideal, but it’s better than total ignorance.
At least there is a chance that they’ll look at
the rule before they make a bad decision.
■ ■ Level two: Understanding is achieved when
a person knows there is a rule and they know
what it says. This is certainly better than the
first level of understanding, but it falls short of
what’s often required to comply with the rule.
■ ■ Level three: Understanding is achieved when
a person knows what the rule says and knows
how to apply the rule in the real world in a
wide range of situations. As a trainer, this is the
level of understanding you want your students
to achieve to ensure they know how to do their
jobs in accordance with company expectations.
It’s important to note that there is a significant gulf between knowing what a rule says and
knowing how to apply it in the real world. It’s
the difference between knowing how the chess
pieces move on the board and knowing how to
play the game well. Consequently, helping others
achieve a level three understanding requires
more than merely tossing the company policy
manual on their desk and asking them to certify
that they’ll comply.
2. Improve understanding through engagement
Dr. William Glasser, the famed psychiatrist, is
quoted as saying, “Learning must be experienced.” He also observed that we remember:
10 percent of what we read;
■ ■ 20 percent of what we hear;
30 percent of what we see;
50 percent of what we hear and see;
70 percent of what we discuss with others;
80 percent of what we experience
■ ■ 95 percent of what we teach to someone else.
As it turns out, there is no data supporting
these numbers. The reality is that we often
learn by a combination of all such activities.
However, I think there is an important kernel
of truth to the basic observation that people
learn best when they are actively engaged in
the learning activity.
Unfortunately, one of the worst training techniques is the most common — teachers reading
from a projected slide. A better approach is to
supplement such informational lectures with
scenario-based workshops where participants
Compliance Training Fundamentals
voices james a. nortz
20 ASSOCIATION OF CORPORATE COUNSEL