Practical insights for compliance and ethics professionals and commentary on the intersection of compliance and culture.

Using ethical dilemmas for creating a compliance training dialog

For effective compliance training, learners must be prepared to discuss and challenge dilemmas independently and with others. The details of specific policies, directives, and regulations can quickly become very dry and irrelevant, whether the audience is made up of compliance officers, senior managers, or new starters. To prevent topic fatigue and keep important compliance training vivid and engaging for those attending awareness sessions, it is important to encourage discussion. An active participant will think, care, and learn more than one who is just watching the clock for the end of the program.

One way to spark discussion that can be employed at all levels is using ethical dilemmas. This is effective either as a stand-alone program, where attendees are introduced to ethical dilemmas and spend time in groups discussing their ideas and views, or as an icebreaker to a content session, to grab the audience’s attention and test their knowledge from the beginning. This can provide an approach to then thinking about the practical handling of compliance subject which is both easy and enjoyable.

Considering and responding to ethical dilemmas helps learners to build fluency with ethical decision-making and evaluating potential conflicts of interest, especially in balance with their own possible interests. Giving meaning to the impact of behavior and choice is significant for establishing cultural values that emphasize individual responsibility and integrity. Dilemma analysis involves several simple but thought-provoking steps following the prompt:

  • What is the ethical question?
  • What personal values are relevant in considering this ethical question?
  • Who are the parties with interests in this dilemma?
  • What are their interests and how do they conflict?
  • How can the ethical question be answered and what are the potential consequences?
  • What is the decision in response to the ethical question?
  • Is the choice that came from the decision-making process of the dilemma possible/practical to do in light of all considerations and consequences?

Ethical dilemmas used as such for prompts in compliance training should be universal and straightforward. In general, dilemmas used to teach this style of thinking to beginners or to instigate audience participation in at the start of a session should not focus on specific employee responsibilities or business functions. For very advanced and targeted audiences it may be acceptable to give a anonymized example of a dilemma they may come across in their work, but for the most part, daily life dilemmas are more relatable and more fun to discuss, regardless of the experience level of the participants.

Some examples of simple dilemmas that can be analyzed as described are:

  • You are meeting some friends at a standing room-only concert and arrive late. As you approach the venue you walk past your friends, who are got there early and are waiting near the front of the line. They tell you they have been there for almost two hours and invite you to join them where they are in the line, even though the end of the line is very far behind them.
  • Your company has been considering some wellness initiatives to offer to employees as benefits but hasn’t contacted any providers yet. Your roommate just finished yoga teacher training and wants to get experience as a corporate instructor.
  • You are taking an exam after studying hard for days to prepare and attending every class the entire term. However, you woke up this morning with a terrible cold and can’t focus. You know the professor will not allow a rescheduled or make-up test. There is no proctor in the room and you have all of your course material with you.
  • You and your partner have a joint bank account where you are both named. Your partner is one week into a two week trip abroad when a letter comes from the bank. You have to fill out and return a form with both your and your partner’s signatures. If you don’t return the form within two business days you will not be able to use your credit card.
  • You are taking your relative to an urgent doctor’s appointment. The parking lot is quite busy but all three of the parking spots designated for disabled drivers are empty. Your relative has no problem walking, but you are already five minutes late for the appointment.

Choosing simple prompts like the ones suggested above will allow the learners to be more creative and perhaps to even engage in discussion with themselves. The facts may be straightforward, but the huge array of perspectives and outcomes that people can suggest is always impressive. By keeping the dilemma prompt at a level everyone can understand regardless of his or her own background and initial interest, the dialog can be truly inclusive. This allows the person who is running the training session to fall into the role of a true facilitator, which offers the enriching experience of watching individuals converse organically on these provocative questions.

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