[00:00:01] Speaker A: Hi, this is Julia Boyes. You've got questions and we've got answers. Thanks for tuning in to today's episode of BELA Asks.
Ethisphere's Business Ethics Leadership Alliance, or BELA as we like to call it, is a community of organizations committed to maturing their ethics and compliance programs and improving their speak up culture.
BELA members can do this through attending events, looking at resources, data, having peer connections, and more.
One really special part of a BELA membership is our concierge service where BELA members can submit questions and our internal experts give curated answers to help answer the BELA members specific questions.
But because we believe that there is no competition in compliance and we are not interested in gatekeeping best practices, we developed BELA Asks a podcast as a part of our Ethiicast so that we can bring you some of the most frequently asked and very important and pertinent questions today.
Now we are very honored to be joined by Ethisphere's Chief Strategy Officer and Executive Chair of Bella, Erica Salmon Byrne.
Hi Erica. Welcome, Julia.
[00:01:22] Speaker B: Thank you so much for having me. And I was particularly excited to come on today's BELA Ask because I just saw in the monthly wrap up that our team does that this year. So it's mid November, we have received over 300 BELA asks. And so if you think about the volume of the questions we get, the fact that we have this chance to bring answers to our community is a really special thing we get to do.
[00:01:48] Speaker A: Yes, I love that. Thank you so much for sharing that. I think today's question is a great one to add to that mix. We got a question from a BELA member and they asked what are your opinions on test out style training and if you could share a couple examples where that's a good option.
[00:02:06] Speaker B: Yeah, absolutely. I like this question for a couple of reasons, Julia. First off, we get this a lot. So thematically speaking, we get a version of this question, oh, I would say every other month or so. So I'm glad we're finally tackling this one on the Bella asks. The second reason I like it is it says to me that this is a BELA member who is thinking very strategically about the purpose of training in the first place. And the purpose of training should be, I say should, educating your employees, right? Giving them information they can use to make better decisions at work. Unfortunately, often training is not bad and is instead a check the box exercise so that in the event you get in trouble down the road, you can demonstrate that you trained the particular employee. And so the thing I like about this question is this says to me, this BELA member is thinking about what is it I want my employees to experience, what is it I'm asking them to engage with on behalf of the program and is there potentially a better way that I can engage that particular employee or engage in that particular type of engagement?
Now, for many, many years we've had the capacity to test out, but there's been a reluctance to do so because we weren't entirely certain and quite frankly, we're still not certain about what the regulators would think about Test Out. And so, you know, we've had a lot of companies over the years who have said, I'd love to do Test Out. My executives would love us to do Test Out. The people have been here forever. I'm going to have taken my FCPA training 15 times. Would love, you know, the ability to test out, but I'm really nervous about doing it because I don't know that the regulators would accept it as a practice.
And I think what we're seeing now is we're seeing companies say, you know what, if I have a risk based reason for offering Test Out, I'm going to start experimenting. And so what we're starting to see right now is we're seeing companies engage in what I would call Test up.
So instead of getting the basic FCPA training, maybe I take the test at the beginning of the training and I demonstrate that I am comfortable enough with certain concepts in the training and so then I get the harder version. Right. So think of this as like, you know, testing into French 201 when you get to college. That same sort of concept where, you know, I've, I've demonstrated that I'm comfortable with the base knowledge. And what I'm going to do is I'm going to get to, to engage with material that is a little bit more advanced. So that's one thing we see companies doing and that is something that we see companies doing primarily around specific topics and primarily around, you know, things that, things that companies train on. Every year Test out is a little different because with Test Out, I'm actually testing out of taking any training at all.
And so Test out becomes something that is more challenging because you have to think really carefully about what are the questions that I am asking my employee to respond to in the moment where I'm engaging with this testing exercise, the test out piece. What does it look like to be engaging with a hard enough test that it demonstrates that the employee really understands what we're dealing with and that becomes something where it's very Scenario driven. Right. The ones that I've seen that are good are test out options where you are really forcing an employee to engage with a certain fact pattern that demonstrates that they understand the material enough that you're comfortable, they're making the right choices at work.
So those are a couple of thoughts on that. I will say, I think some of the reason we're getting this question so much right now is some of the media coverage of the fact that agentic AI will now take your training for you. Like you can tell an AI agent to take your training for you. And so I think that is causing some soul searching, as it should, amongst compliance officers as to how do I still make sure that my material is actually educating employees? How do I make sure that these aren't AI agents that are taking training on my employees behalf?
And you know, what could, what could better look like? Now? Look, to be honest, we've had executives who have had their assistants taking their training for them forever. So agentic AI is not that different. It's just open to lots of people in a way that, you know, historically speaking we have not had that kind of support.
But I think asking yourself the question of what is training for in the first place is an important piece of the puzzle.
[00:06:36] Speaker A: Do you have time for just a quick question, quick follow up?
[00:06:40] Speaker B: Julia, longtime listeners of BELA asks. No, I always have time for a follow up.
[00:06:45] Speaker A: Yeah. So if a company were to engage in, opt out or even opt up, would you still encourage them and like what would be a cadence that their, their employees should then have to, I don't know, either retake it or opt out or up again?
[00:07:01] Speaker B: Mm, yeah. Yeah. This is a really, that's, this is a good question.
You know, the most companies that I have seen that do sort of test up, you can test up. They don't really have a, they don't have a point at which you have to go back and re engage with the basic material. Now you can, you can fail the test up.
So you know, let, so I would certainly say just because somebody has tested up in one year, I wouldn't then assume they're going to be able to test up forever because they may or may not remember the concepts that you're testing on. So having someone go through that test up process is something I would definitely recommend. Even if it means that forever they're just, you know, they pass the test up and they go and engage with the more sophisticated material, still have them go through that process of being able to demonstrate that they understand the topic enough that they can go on and engage with something more sophisticated on test out, where I am not engaging with any training and instead I'm passing a test to demonstrate I don't need to. What I have seen there most commonly is you can't test out or you can't. Yeah, you can't test out. Not test out, test out forever. So you ha. At some point you need to go back and re. Engage with the training. And again, you could do that based on the test, you know, where do I start to see declining scores? Or you could do that based on some sort of a predetermined cadence, you know, every two years, every three years, something like that. So you can only test out of something for so many years in a row. The one thing I will say is we rarely see test out in code training just because that is something where, you know, it's, it's, it's as much a cultural experience as it is an educational experience. You are, you know, it's such a foundational document. We do see test up in code training. So I might get the harder quizzes, I might get the harder scenarios because I've demonstrated a facility with material where we traditionally see a lot of test up and some test out is at that topic specific piece.
[00:09:05] Speaker A: Okay, well, thank you, Erica.
I know I just learned a lot, so I can only imagine how informative this is going to be for the BELA community. So thank you for your time.
[00:09:14] Speaker B: Thank you so much for having me back. I really appreciate the opportunity to keep answering these questions and to all those Bella members out there, keep them coming so that I get a chance to come back and talk to my friend Julia and share our thoughts on some of these thorny issues that are repeatedly appearing in our conversations with the good folks who make up BELA.
[00:09:35] Speaker A: Thanks, Erica. Take care. If you would like to hear more conversations like the one we had today, subscribe to our YouTube channel or wherever you get your podcasts. If you would like to see more resources, you can visit ethisphere.com resources if you'd like to know more about BELA memberships, you can always write to us at
[email protected] and most importantly, if you have a question that you would like featured on an upcoming episode of Bella Asks, please reach out to us. We love to hear your questions and we love to give you answers. Thanks for joining us today. I'm Julia Boyes and this is BELA Asks.
