Effectiveness Beyond the Compliance Program

An Increased Focus on Measuring Behavior

In 2018, all signs point to an increased focus on measuring behavior and a deeper understanding of program effectiveness. Learn more about this trend below, and read all eight of SAI Global’s trends and predictions here.

Advances in ethics and compliance training technology and learning management systems (LMS), as well as a growing maturity within ethics and compliance (E&C) programs, implies that, in 2018, Chief Compliance Officers will have more data and insights into their programs than ever before. This will help compliance officers learn more about what does and doesn’t work in their programs, and what resonates with their employees.

While a growing focus on data and analytics is not a completely new trend, it is an increasingly important one worth highlighting as we look at the next 12 months. More and more, organizations are looking for relevant metrics and powerful analytics that better calibrate their E&C practices and risk governance strategies, as well as an increase in the impact of their interventions. The trend demands access to insightful data, predictive analytics, smart dashboards and comprehensive data architectures.

The constant need to collect data that helps quantify program effectiveness has made strides in the right direction, but compliance officers are still not measuring everything they can or making the most of the data they collect. The notion of program effectiveness and impact is evolving, and with that evolution comes accelerated internal pressures stemming from the increased attention placed on corporate culture and compliance training in light of recent scandals and media coverage.

We know that we need training and learning solutions to do more than just increase an employee’s basic levels of knowledge and understanding. To truly change behavior, what they learn needs to be supported by context, emphasized by leadership, reinforced in conversation and driven home by a cultural focus on ethics, values and doing what’s right. If we can agree on that, then it’s time to think about how we measure more than just the effectiveness of programs, because the program alone is not what changes the behavior.

Earlier this year, Richard H. Thaler, a professor and author whose bestselling book “Nudge” focused on human behavior and decision-making, won the Nobel Prize in Economics. Why does this matter? As reported by The Wall Street Journal, Thaler’s work with the U.K.’s Behavioral Insights Team has led to the British government adding behavioral sciences research to their anti-corruption efforts and compliance innovation initiatives.

The recently published United Kingdom Anti-Corruption Strategy 2017-2022 details the government’s vision and priorities for combating corruption. A significant part of the plan is to apply behavioral sciences to anti-corruption and, to accomplish that goal, the British government is partnering with governments in Colombia, Mexico and Argentina to support research projects that will test how this approach can be applied to supply chain, third-party relationships and reporting.

“In making behavioral sciences part of its anti-corruption strategy, the U.K. is taking a more sophisticated, thorough approach to understanding what is driving the behavior. It is making it a priority… and leading by example; if the government is looking at behavior, it will expect the same from companies.” – Amanda Raad, Partner at Ropes & Gray

As our understanding of human behavior and what motivates corruption and unethical acts continues to grow, even more attention is being paid to the impact this knowledge can have on ethics and compliance programs. Rules alone cannot achieve what needs to be done, because rules are made to be broken.

Our Prediction

In 2018, we’ll see organizations change their perception around “program effectiveness” and look at developing a deeper understanding of culture and behavior. Advanced ethics and compliance departments will look beyond program analytics, which simply measure various aspects of the training and content that is delivered to their employees. Instead, these departments will look to a deeper and more meaningful set of analytics and data that looks to measure behavior and how that behavior impacts the company.

Just as training alone cannot change employee behavior, program effectiveness alone cannot truly reflect if employee behavior is changing in a positive way. As part of this trend, training and advisory solutions that are actually able to affect behavior will become key culture drivers.

As this trend becomes more endemic, organizations will be faced with the challenge of managing the confidentiality and anonymity of the data they access. Solutions that guarantee transparency, stick to their intended use and avoid focusing on individual records will be better suited to deliver insights free of ethical breaches.

To read more thoughts on the proactive and reactive evolution facing our industry, download “The Future of Ethics, Compliance, Risk, and Corporate Culture: 8 Trends and Predictions for 2018” from SAI Global.