
Standards for waivers of conflicts of interest
While some organizations bar conflicts of interest in all cases, many opt for allowing COIs to exist where appropriate. But how should appropriate be defined for these purposes?
by Joe Murphy
Is it a good idea for governments to mandate specific length and frequency of compliance training? One of the most problematical examples is California’s requirement for 2 hours of harassment training, every 2 years (with no requirement that you ever evaluate the effectiveness of the training!).
What does this tell people? Have a stopwatch handy, and count out 120 minutes. When the watch is done, you are done. No more training for another two years. Yet what if studies show shorter, more engaging training or brief messages, spread out over time, are actually more effective in reaching people? Sorry, that doesn’t meet the official standard. Some in government believe all they have to do is mandate specific compliance steps and they are done. But this freezes development and innovation. Mandatory compliance also typically does not bother to require that you assess the training and fix what does not work. And it can lead to what is called “malicious compliance,” where companies follow the letter of the law but negate the purpose. For example, people in the “mandatory” training may spend the 2 hours on their smartphones.
We need to keep experimenting in how we communicate. We need to keep assessing what works. But we also need to push back against mindless government dictates that undercut what we are trying to do.
While some organizations bar conflicts of interest in all cases, many opt for allowing COIs to exist where appropriate. But how should appropriate be defined for these purposes?
Attending SCCE conferences is always a source of insights and new information. In these conferences I have seen quite a bit of focus on data analytics, and deservedly so.
The first time I saw Kristy Grant-Hart she put on a show about magic compliance dust and then brought the audience to reality by breaking the news that there is
In our years of assessing compliance and ethics (C&E) programs, my partner Jeff Kaplan and I have pinpointed several key attributes that we consider essential to an effective program, including