Reduce risk and save money by targeting conduct and compliance training

The challenge: a well-written Code that wasn't guiding decisions

Why train 30,000 frontline staff on money laundering rules they will never have to apply?

A large hospitality employer came to Acteon after their audit committee saw a rise in conduct-related issues. Their Code was well written, but colleagues struggled to apply it to everyday work. So instead of automatically prescribing more training, we started with what they already had, to understand what was working and what wasn't.

Their Code of Conduct training consisted of one universal e-learning module with limited reinforcement - it was very much a sheep-dip approach. And with no role-based personalisation, frontline colleagues completed training on money laundering, tax evasion and procurement risks even when these risk areas had nothing to do with their day-to-day responsibilities. Across a workforce of this size, every 30-minute training module completed by someone who doesn’t need it means thousands of hours of paid time wasted.

Managers branded elements of the training as a “tick-box exercise” while employees struggled to recall key messages.

Workshops, interviews and site visits showed that behaviour standards were generally good, but the Code was not what was guiding them. Everyday conduct was shaped by local culture, colleagues and managers, and it varied from site to site. Not everyone had the same understanding of how the Code could guide decisions in challenging situations or how to confidently manage risks.

The approach: make it relevant, reduce training time, save money

We recommended replacing the one-size-fits-all model with practical and relevant support for different audiences, risk areas and the typical moments where responsible decision-making is key.  

Different roles and sites faced different levels of risk. They therefore needed different levels of information, practice and reinforcement. What we recommended:  

• matching training to each role and the organisation specific risks it carries
• using real role-specific situations
• giving managers practical tools to support conduct conversations
• connecting guidance to clear actions and sources of support, so people know what to do next
• replacing the single annual event with a year-round drumbeat of short learning moments, resources and communications that keep the Code top of mind

Instead of expecting employees to retain every message from a 30- to 45-minute module, the organisation could reinforce the right behaviour closer to the point at which it was needed.

The value: better decisions, at a lower cost per head

The time people spend is now dependant on the risk areas their own role carries, so they finish with a clearer understanding of how to use the Code for responsible decision-making in their daily work. Less time spent on content that does not apply also means a lower cost per head.

Rather than making training completion the end goal, the approach focused on whether employees could recognise a moment of potential risk, make a sound choice and take the right next action.

Acteon insight: A Code of Conduct only protects an organisation if your people can use it. And completion alone doesn’t tell you if people are supported to make the right decision under pressure. By targeting messages, reducing learning waste and sustaining a conversation throughout the year you can foster a culture that supports responsible and ethical decision-making.