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Tuesday, November 07, 2017

So, what disaster led to this mandatory training?

A few months ago, there was mandatory business ethics training at a company I consult for. Now, today, there's this further training from the same company:
"Recently, [CEO] announced the adoption of our revised Code of Conduct that outlines the standards of integrity and ethical behavior that should guide all our decisions and interactions at [Company].
In order to help you [!!!!!!] ... we are announcing a new mandatory training program for all employees. ...
This mandatory training is required ... and must be completed no later than [9 business days from now]."
What the heck. I'm paid by the hour.

😉But what I want to know is: WHO SCREWED UP, AND JUST HOW BADLY DID THEY SCREW UP that they need two mandatory training programs plus a new official Code of Conduct? 😉

It's hard not to be curious.

A second possibility

A second possibility is that this is all CYA: the company knows this stuff might be / is going on, and wants to be able to say "Don't blame the executives; we explicitly told everyone not to do that.", even though there may be subtle encouragement to engage in such practices.

This is what might be termed the Wells Fargo approach -- employees had official directives not to do things, and were fired when they did them, but corporate reaped big bonuses for subtly encouraging such practices AND not monitoring the employees for compliance with the account opening policies.

As to the third possibility -- that this is all sincerely meant -- I will point out that I spent my working career working in large corporations. That possibility seems so unlikely I'm not even going to consider it.


Consultant takes no responsibility whatsoever


While this Code of Conduct and mandatory training certainly provide the opportunity for the employee to be fried for noncompliance, those designing the training course clearly want to take no responsiblity whatsoever (emphasis added).

This course was developed with subject matter support provided by [some firm LLP]. Please note, however, that the course materials and content are for informational purposes only and do not constitute legal advice and may or may not reflect the most current legal developmentsNothing herein, or in the course materials, shall be construed as professional advice as to any particular situation or constitute a legal opinion with respect to compliance with legal statutes or statutory instruments. [Some firm LLP] accepts no responsibility for their contents and the reliance on the contents is prohibited and at the user's risk. Transmission of the information is not intended to create, and receipt does not constitute, a solicitor-client or attorney-client relationship. Readers should not act upon this information without seeking independent legal advice.

It's not just me. This training is just CYA for employers 

Addendum: Some days later (Nov 17, 2018) the Washington Post had a nice article summarizing the real purpose of such training (specifically sexual harassment training):

there is little evidence that training reduces sexual harassment. Rather, training programs, along with anti-harassment policies and reporting procedures, do more to shield employers from liability than to protect employees from harassment.