The Anti-Corruption Report spoke with Manatt’s Jacqueline Wolff, co-chair of the firm’s corporate investigations and white collar defense practice, for the third of a four-part series on measuring compliance. This issue focused on how to measure quality.
According to the publication, there are many ways to measure the quality of a company’s compliance program, but they can be labor-intensive to design and implement. “Companies can become so data-driven that the most effective ways of assessing a compliance program—which are often not data-driven and require one-on-one interactions—can get lost,” said Wolff.
One method for performing a qualitative analysis of a company’s compliance program is the in-person interview. Wolff explained that these interviews give employees opportunities to ask questions and engage in discussion. “During those interactions,” said Wolff, “the trainer can get a much clearer sense of whether the employees truly understand the training and, more importantly, can learn whether there are ongoing compliance issues in that field.”
Wolff also commented on using hypothetical situations to spark discussions with employees, which can reveal information about the effectiveness of a compliance program.
“Rather than giving a simple multiple-choice test at the end of a training session for high-risk employees, a company could give a more in-depth exam with hypothetical situations and narrative answers,” Wolff explained. “That kind of exam would generate a more accurate metric of the effectiveness of the compliance training.”