‘Telephone Training’ - The compliance benefits of combining trust with checking


by Keith Read

Back in the 1950’s and 1960’s the psychologist Frederick Hertzberg set about understanding the fundamentals of employee satisfaction, which resulted in his now famous two-factor or motivation-hygiene theory; his theory states that there are a number of factors in the working environment that provide job satisfaction whilst a separate set of factors cause dissatisfaction, all of which act independently of each other.

Drivers of dissatisfaction can include, for example, salary, status and conditions whereas drivers of satisfaction can include achievement, responsibility,  recognition and – crucially – trust; all of these can be core to addressing the challenges faced by compliance and ethics officers, and achieving genuine engagement such that training, for example, isn’t treated as a chore, completed in ten minutes at 5pm on a Friday evening just to ‘tick the box’.

Hertzberg’s theory was in the back of my mind when I decided to focus on all the opportunities that the compliance team had to engender, demonstrate and increase trust, which then meant that compliance checking and testing was seen against that positive background, and so perceived in a completely different light.

My company had more than 30,000 engineers on the road, so getting them off the road to do their compliance training was a huge logistical challenge and customer service issue; even when they were taken off the road, compliance training was sometimes only given scant regard – paid ‘lip service’-  in some locations and teams. Some people had laptops, but many didn’t which only added to the challenges – and doing it on their phones to me had all the potential hallmarks of a de minimis type of outcome; treated with insufficient importance so as to just get it out of the way – with the result that genuine learning was sacrificed.

Instead, as outlined in ‘The Unconventional Compliance Officer’ on pages 101 and 102, what I did was to develop intelligent but low-cost ‘telephone training’. Our engineers entered their employee ID number at the start, listened to the training, could easily rewind and repeat if needed and also then answered some multiple-choice questions at the end to confirm their learning.

However – crucially – I got agreement to give them an hour’s overtime to do their training off-shift, at home or wherever worked for them. Subsequently, all the feedback was that – perhaps for the first time – they felt trusted, and the contact and questions we had only confirmed that they were genuinely engaged. Moreover, from the call durations and other information, it was apparent that many had reviewed elements of the material several times, so their engagement was not in question. Crucially, the hour’s overtime was a largely displacement cost i.e. we would have had to pay many of them that money to get customer service back on schedule, such that it cost us little more but generated much, much better outcomes.

Having established that level of trust with this and other techniques, then the checking/testing that we were also doing was seen in a different perspective – not least of all because it was no longer seen as a chore, people were engaged, had a greater understanding of the real risks and wanted to demonstrate their contribution; completing their training without immediate and direct supervision also moved them away from what some historically perceived as a ‘big brother’ approach.

Ultimately, we got to where we wanted and it was a genuine win-win-win – for employees, the company and the compliance team. Failure to check/test can lead to a raft of serious consequences and so it is invariably a necessary tool, as part of a wider environment of trust, but trust and test or trust and check is always going to be crucial and – positioned well – people will understand (and support) that.

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