An effective training program is a foundational element for any company committed to doing business ethically and in compliance with the law. Not only does training prepare employees and third-party intermediaries for difficult situations they might encounter, but it also contributes to a company culture that prioritizes compliance, provides context to real-world issues and bolsters internal reporting mechanisms, such as hotlines — all essential to driving the global, anti-corruption agenda forward and reducing the risk of legal, financial and reputational issues. The U.S. and anti-bribery enforcement authorities have repeatedly emphasized the importance of building a baseline of standardized, shared compliance knowledge across a company, including among contractors, suppliers, distributors and sales agents.
Saudi Basic Industries Corporation (SABIC), a global leader in chemicals headquartered in Riyadh, Saudi Arabia, has developed a process customized to each type of third-party, business partner to efficiently create a stronger and more secure supply chain.
A Tailored Approach to Training
Ranked among the world’s largest petrochemical manufacturers, SABIC has operations in over 50 countries with a global workforce of over 32,000. SABIC trains a large number of third-party intermediaries — including suppliers, distributors and temporary employees — across its supply chain. Through a tailored approach, SABIC identifies and addresses gaps in third-party intermediaries’ compliance policies and procedures.
As a starting point for each supplier, SABIC completes a due diligence evaluation to identify policies and procedures for anti-bribery, anti-money laundering, avoiding child labor, avoiding forced labor and economic sanctions compliance. Based on the results of the due diligence evaluation and further consideration of additional factors by SABIC’s compliance department, SABIC assigns the supplier corresponding training modules. For example, employees of a supplier that does not have a program addressing sanctions compliance may be required to complete an eLearning course on economic sanctions.
Matching training requirements to gaps in third parties’ policies and procedures prevents unnecessary expenditure and duplicitous requirements for intermediaries while addressing critical issues throughout the supply chain.
Distributors working with SABIC are required to complete anti-bribery and economic sanctions training as part of their key performance indicators, and temporary employees are similarly required to complete a suite of training courses on various topics.
Third-party intermediaries are sometimes, perhaps unfairly, perceived as resistant to compliance training. SABIC, however, has found that many suppliers are enthusiastic about the opportunity to learn through an industry leader, recognizing that they are essential to raising the standard of compliance in their respective regions.
Keeping Learners Engaged and Meeting People Where They Are
Training is sometimes viewed as a check-the-box exercise, but it provides an excellent opportunity to build capacity and strengthen the culture of compliance both within the company and extending through the supply chain.
In addition to boosting third parties’ compliance capacity, training also builds confidence with customers, investors, lenders and other stakeholders who want to do business with ethical companies they can feel good about being associated with. They are not satisfied with knowing only what SABIC is doing internally: They want to have visibility into the entire supply chain and know that it is free of corruption, forced labor, child labor, environmental violations and other issues. In order to achieve those goals, compliance training needs to “stick.”
- To keep learners engaged, SABIC’s compliance training incorporates gamification to increase engagement and retention among learners. Courses that include real-life scenarios can help prepare employees and business partners for difficult scenarios, such as being asked for a bribe or uncovering sanctions violations.
- In addition to standing up to legal and regulatory scrutiny, an effective training program must also be equipped with multilingual capabilities. Those administering training should consider local customs — for example, not scheduling required training near local holidays when employees are likely to take time off.
- Requiring periodic “refresher” courses is an effective way to increase knowledge retention and can be customized depending on the risk level. Shorter in length, these courses are designed to remind learners of topics they’re already familiar with.
SABIC has found tailored compliance training to be an effective way to create a shared baseline of knowledge among employees and its extended supply chain. Addressing gaps in third-party intermediaries’ policies and procedures on a case-by-case basis allows the company to increase efficiency without compromising comprehensiveness.
SABIC’s third parties have generally been receptive to the training. In particular, smaller companies that do not have the resources to put together their own training programs are appreciative of the opportunity to offer their employees online training in the local language. This helps to bolster the company’s relationship with its external business partners. Given the success of the program to date, SABIC plans to continue its third-party engagement efforts going forward.