For purposes of global anti-bribery compliance, the importance of basic training can never be overstated. All too often in recent years, more traditional forms of basic training, such as classroom sessions, meetings, in-house seminars, are perceived as being terribly mundane and, in the current environment of sophisticated technology, deemed to be archaic and unduly time consuming. As a result, the effectiveness of basic training is not given the attention that it deserves.
What is often overlooked is the time it takes to change a way of thinking that may be endemic to the culture of an entity. Whether it be smoking in the workplace, sexual harassment, or other dramatic shifts in what may be permissible in a workplace setting or when acting on behalf of an entity, it must be kept in mind that incredible amounts of time and effort were and continue to be required to change mindsets as to what may no longer be acceptable. It is a process that takes time, repetition, and ongoing efforts.
Fundamental to any entity’s culture is that change is almost impossible until there is a change in mindset. In many instances, officers, employees, and those acting on behalf of an entity may not have thought that accepted practices could be problematic. Indeed, it is not uncommon for even sophisticated officials within an entity to be insensitive to the subtle nature of potential violations. People need to be trained as to the overarching issues and, in particular, the type of things that should draw their attention or that should otherwise be avoided.
Entities should not be discouraged from pursuing new technology that may be of assistance in facilitating training and heightening the level of compliance. But ongoing reliance on basic training should lie at the core of any compliance program. The interchanges and give and take associated with any live, in-person training can be invaluable in assessing weaknesses and the level of understanding within an entity and with those acting on its behalf.
