Joe Murphy – Compliance & Ethics Professional – October 2017
One question that sometimes comes up, especially regarding new employees or those who are newly promoted, is when do they need to be trained? How long can someone be a new employee or in a new job before they get compliance training? Years ago, when training usually had to be live, it was a question of when you could get the training out for a group or location. Today there are media that can provide some form of training on very short notice.
But when must the training take place? Consider this scenario:
A manager with more than ten years’ experience in the business is given a new assignment managing a sales team. Being the diligent type, she makes a point of meeting with key people, including, within a month of taking her position, a supplier’s rep.
The rep’s company supplies a product that her company sells but his company also sells, sometimes in direct competition. He is very cordial and wants to maximize cooperation between the two companies. He says that the two companies can and will continue to compete, but he suggests the competition just not be on price. That way they both do well in the marketplace. That seems reasonable to her, so she advises her sales people to ease off on price breaks and just tout their company’s own excellent service. After all, this supplier has been working with them for years, and she wants to retain a good relationship.
One month later she has the company’s antitrust training. When she hears that she should not discuss price competition with a competitor (even one who is also a supplier!) she realizes she might have done something wrong and calls her general counsel.
When did she need to be trained? Some would think that getting the training within two months of taking a new position was fairly diligent. But that was too late for her.
Consider this question: When should a new driver get training on how to drive a car? After they have been on the road for a while? Of course not, that is crazy. But then why is it also not crazy to put a new employee or manager in harm’s way without telling them how to steer and when to use the brakes? How can we put someone in a position managing sales without first telling them where the danger spots are?
We need to know the risks associated with each position. Each person going into that position needs the appropriate training before they take the position and before they can do any damage to themselves or the company. It is the only smart way for the company and the only fair way for the employee.