Discrimination and Harassment
September 30, 2022
Scott Schneider, Head of Content Development at Traliant, spoke with Tom Fox on the Compliance Podcast Network about the evolution and challenges of anti-corruption training. The interview has been edited for length and clarity.
Tom: What’s the key to providing effective anti-corruption training?
Scott: I think most people have an intuitive understanding of what corruption is – at least at a very high level. They understand you can’t pay government officials or others for favors.
The key to providing effective training is to translate the high-level principles into practical guidance. What do you do when your product is stuck on a loading dock someplace? Is it okay to slip someone 20 dollars? Who do you talk to in our organization?
I think you also need to shift the training perspective to that of the employee. You’ve got a lot riding on the actions your employees take and want to help them make the right decision. For example, a customer once told me its employees understood that you can’t give money to foreign officials, but then sent agents gift cards – as if that was somehow different. With anti-bribery training, you need to look at issues through a broader lens and ask yourself, “Are we doing our due diligence to make sure people are doing things correctly?
Tom: How should a company think through who needs targeted training?
Scott: You need to understand where potential risks lie and how to intercept them. You can begin to address risks by assessing what you do and how you do it. Start with the areas of greatest risk, and work down from there. Make it a priority for employees to understand and follow rules and provide additional targeted training to people who are in a position to help others.
It’s also important for employers to understand who their audience is. What’s pushing their buttons? What do they care about most and what do they fear the most? Understanding those things is a big step forward in understanding who needs targeted training and how to impact them.
Tom: Can anti-corruption training reinforce corporate culture and visa-versa?
Scott: I think it can and should. You can support culture by linking training to a company’s values and what leadership is saying and doing. If you have the right initiatives and incentives in place, anti-corruption training can become a powerful motivator because you’ve made it clear to people it matters.
Most employees are rational. If you clearly identify what you want them to do and properly align incentives, they will do it. It’s important for employees to understand that they shouldn’t bend the rules or cut corners and that there are people at the company who can help them navigate complicated issues to get things done in the appropriate way.
Tom: Do clients understand that it takes leadership setting the right tone, a compliance culture and anti-corruption training to create an ethical work environment?
Scott: I think so. Training is a necessary element for success – but it’s not the only one. You need all three working together.
Mind you, there are nuances that trip people up. But often the issue isn’t just understanding. Afterall, when someone gives a foreign official $10 million or buys them a condo, they understand exactly what they’re doing. The real issue in many cases is whether management will support employees who walk away from a deal where the only way to get it is through a bribe, kickback or some other illegal payment.
So why do individuals sometimes commit unethical behavior? Maybe they thought they’d get a big paycheck or promotion if they closed the deal. Or maybe they feared they would be fired if they didn’t deliver for their employer. That’s why successful anti-corruption programs look at training needs, how leadership sets the tone and the kind corporate culture that is embraced.
Click here to listen to the entire Compliance Podcast Network interview with Scott Schneider.
Scott Schneider, Traliant’s Head of Content Development, is a compliance professional and former attorney. He brings more than two decades of compliance experience to create impactful training solutions that help employees explore and understand critical compliance and workplace issues.