Table of Contents
On this page:
- What this means
- Why it matters
- How you can conduct effective training and communication
- Tips for effective training and communication
What this means
Everyone in your organization should know what they need to do to operate within the law — from the board and senior leaders down to front-line staff. Employee and management training and compliance communication are critical for the effectiveness of any compliance program.
A small reminder on what makes a compliance program credible and effective
Your compliance program needs to be credible and effective to truly help you.
To be credible, your program must at a minimum show your business’ genuine commitment to obeying the law and competing fairly.
To be effective, your program must inform all your people, and those acting for your organization, that compliance is important. It must inform them of their legal duties and your internal compliance measures. It should also give you the tools to prevent and detect misconduct.
Your program should be reasonably designed, implemented and enforced in the circumstances. This means that it addresses your organization’s risks within your resources and in light of your business activities.
Why it matters
The objective of a compliance program is to stop people from breaking the law. Employees and management alike need to understand what is acceptable business behaviour and what is unacceptable. They all should know what the law prohibits and the consequences for not following the law. Training employees and communicating your principles and program can help everyone be vigilant.
Regular communication with employees at all levels of your organization conveys your management’s commitment and support to build a culture of compliance.
If you’re a small business...
Training managers and employees and communicating the benefit of compliance to all employees does not have to cost a lot. You don’t necessarily need to buy expensive learning management systems or hire an external lawyer to offer credible and effective compliance training. For example, you may use time during all-staff meetings or informal gatherings to talk about how compliance is important. You could also use team meetings to train employees. Take advantage of free publications and compliance tools from the Competition Bureau. Consider whether your industry or trade association offers or could develop compliance training resources.
How you can conduct effective training and communication
Your organization should choose training and communication methods based on your size and risks.
A credible and effective compliance program should include training on:
- the parts of Canadian law that apply to your operations
- your compliance program, including the specific policies, procedures and controls for employees in at-risk roles.
Who should be trained?
Train all senior executives, managers and staff on your overall compliance program, especially the reporting system and code of conduct.
For those in at-risk roles, you should provide additional, mandatory training on competition and deceptive marketing issues.
You should not only train your full-time, permanent staff, but also:
- employees who have joined your organization as secondees from other companies
- temporary workers in at-risk roles
Be vigilant about those your company deal with to minimize your company’s exposure. Consider whether those people in the following positions have been adequately trained by their employer:
- employees of services providers
- dealers, distributors and contractors
- any person who a third party might believe represents your organization
When should they be trained?
- New hires: New hires in at-risk roles should complete training as part of assuming their duties. Other recently recruited staff and senior executives should not be exposed to risk until they have been trained and know what to do.
- At-risk roles: Training on competition and deceptive marketing issues should be updated regularly.
Management support
Managers should always be highly visible in promoting compliance training to employees. This visibility creates a culture of accountability. To encourage everyone to take compliance seriously, managers should:
- take the training themselves along with the employees
- talk about the program in emails, meetings, presentations and other speaking engagements
- firmly reject any action that could break the law
- deliver training and communications along with compliance staff, if they are well versed in the law
Tips for effective training and communication
Effective compliance training and communication is:
- relevant: relates to real life situations faced by your organization
- engaging: involves your employees and management
- well-designed: uses different modes of training and communications which are best suited for the target audience and subject matter, and evaluates how your training is actually working
Relevant
Use illustrations:
- Give simple do’s and don’ts to your people.
- Use examples that directly relate to the work your organization and employees do.
- Include real cases where people and companies paid the price for breaking the law.
- Use practical and simple language in your communications.
- Identify situations when employees should seek help.
- Show the consequences of non-compliance.
Keep your staff up-to-date:
- Alert your employees in a timely way about new or changing compliance issues.
Engaging
Train in teams:
- If resources and expertise are available, you should train your employees in groups — in both face-to-face and online training.
- If you can, invite employees with similar roles and responsibilities to the same sessions to benefit from group work and shared insights. This may help employees see the link between the compliance policies and the practical situations they face at work.
Keep it lively:
- Provide plenty of time for interactive discussions and questions in the training sessions. Employees might use these discussions to raise issues that your organization needs to address.
- Actively engage your audience during question-and-answer sessions.
- Offer variety depending on the situation, for example:
- small group seminars and discussions
- practical do’s and don’ts
- realistic business dilemmas
- email alerts
- apps, videos and gamification
- in-person, online or blended training depending on your situation
- workshops
Well-designed
Deliver training effectively:
- Bring in experts, such as your compliance officer or other legal or compliance experts.
- Use trainers who know the law and are skilled at engaging a diverse group of employees using inclusive techniques.
Be consistent:
- Ensure that training and communication messages are consistent.
- If your people are working remotely or in a hybrid environment, make sure the impact of your various training and communication methods is consistent.
- If yours is a larger organization, you might need “train the trainer” programs too.
Be mindful of your audience:
- Consider the various needs of your audience, including language, cultural appropriateness, accessibility and learning styles.
Track attendance but also assess if your employees grasp the content:
- Keep a record of all employees who have completed training. This ensures you don’t overlook individuals or work areas.
- To see if your training is actually working, supervisors should regularly assess the knowledge and attitudes of employees toward compliance policies and procedures.
Build training into your performance reviews:
- Make supervisors’ performance evaluations include ensuring that their team members are trained.
- Consider making training for employees in at-risk roles a mandatory condition for performance review.
If you’re a small business...
In smaller organizations, employees of relevant operational teams can provide effective training. Employees might relate better to the content of the training materials when it is delivered by a colleague whom they know and trust and understands the issues that they face on a daily basis. Make sure the trainer knows the law very well.
DISCLAIMER: Because every situation presents unique facts, the information set out herein is provided for general information only. This content is not a substitute for legal advice, nor is it a binding statement of the Commissioner of Competition’s position on the requirements or efficacy of any particular compliance program. Indeed, there is no one-size-fits-all approach when it comes to achieving credible and effective compliance.
The Competition Bureau launched a Compliance Portal to help you and your business stay on the right side of competition and labelling laws. It replaces the Corporate Compliance Programs Bulletin. We’re currently reviewing the feedback we received during the recent consultation on the form and substance of this portal. An update will follow later this year.