World-Wide Guidance for International Trade & Transactions, Compliance and Ethics
World-Wide Guidance for International Trade & Transactions, Compliance and Ethics
Perhaps it’s better to first note training methods that go only a little way, if at all, to achieving those objectives.
Mass-produced videos watched by employees via the company’s internal website or a dedicated URL There’s definitely a personal advantage to watch training videos at times that fit each employee’s schedule, assuming the urge to multi-task or take a nap is ignored. Even if a viewer devotes 100% attention to the material, these presentations are often “one size fits all” without regard to your industry. For example, in a video addressing bribery, there may be little mention of more than one country’s anti-corruption laws (i.e. the material focuses on the FCPA with only passing reference to “similar laws in your country”) and there’s nothing relevant about the product line featured in the video. Unless you pay for the same material in different languages, you are heavily reliant upon each employee’s ability to understand the material presented in one language; i.e. English.
A “read and obey” approach to global policies and procedures. It’s great to have policies and procedures; however, simply providing those documents for employees to educate themselves on subjects like sanctions, embargoes, boycotts and export controls is woefully inadequate in today’s environment of having a meaningful compliance program in place. Even if these documents have been translated to the employees’ language, have you confirmed with a Human Resources expert that requiring employees in one country to read and comply with policies and procedures created in another country has not created a jurisdiction risk your company thought it was avoiding by operating through a local subsidiary?
Or, you can take this more sound approach:
Customized in-person interactive training. Focused, meaningful and lead by a knowledgeable instructor to help each employee understand how compliance is both an individual and a team effort. The materials are available in the employees’ native language and, if necessary, the instructor is assisted by a local employee to make certain nothing’s lost in translation. Interactive training allows for robust discussion of the subjects and provides the instructor the unique opportunity to listen to the attendees’ concerns and comments, thus providing greater understanding of the company’s global trade compliance. This is one of many metrics not readily obtained from showing videos or taking the “read it and obey” approach.
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