Meeting complex industry regulations, keeping on top of ever-changing data laws, managing risk, all of these challenges demand a water-tight compliance culture. But that’s only part of the story; performing ethically – and being seen to be doing so – has never been so important in our industry’s approach to compliance. Basically, we need to do things right.
And yet many businesses believe there are shortcomings in the effectiveness of their compliance programmes. When PwC surveyed 825 risk and compliance executives across various industries worldwide for its 2018 State of Compliance Study, just 17% of them said they were “very satisfied” with their compliance programmes. PwC describes these as ‘leaders’.
Leaders in compliance
So, what are these ‘leaders’ doing that sets them apart? Firstly, according to the survey, they are using progressive methods in all aspects of risk management to develop effective procedures and practices. As part of this, they are leveraging information and technology to provide targeted, up to date, varied and engaging training. Another difference is that they’re utilising tech-enabled compliance monitoring and analytics to drive continuous improvement.
Which begs the question: ‘If compliance programmes that use these methods are more effective, why aren’t we all using them? Shouldn’t we be learning from the ‘leaders’?’ Interestingly, the survey also found that these ‘leaders’ were more optimistic about their performance and expected stronger revenue growth in the next three years, compared to the other companies.
Embracing the spirit of regulations
The conclusion of the PwC report is particularly compelling. Looking ahead, it says that for compliance programmes to be successful, a culture of values needs to span the whole organisation, from the boardroom to the frontline. It also says we must look more deeply into compliance and ethics. Why are they important? Why should we embrace them? The answer, according to the report, should be this: it’s because we want to do what’s right for our customers and for the wider community. We shouldn’t simply embrace the regulations; we should embrace the spirit of the regulations.
Working with digital learning provider, Sponge, this is exactly what we’ve done at AstraZeneca. We’ve made a conscious decision to move compliance training from a ‘must do’ to a ‘want to do’ activity. This has had a huge impact on the organisation, our culture and people.
Overcoming hurdles
Like all large pharmaceutical companies, we face challenges associated with a global workforce. We have over 64,000 employees (reflecting different age groups, languages, cultures, backgrounds and education levels) operating in over 100 countries worldwide. This presents many considerations when it comes to embedding our values, integrity and ethical principles across the organisation. Added to this, we know that some learners have limited access to, or preferences for, certain devices. For example, our salesforce are reliant on mobile devices. But, regardless of cultural and physical barriers, we need to ensure that all employees are empowered to deliver the same high standards.
AstraZeneca has been conducting mandatory compliance training for many years. However, due to the wide range of job roles and functions within the organisation, we’ve found previous training has resonated with some employees more than others and engagement levels have reflected this. We needed to change our thinking, and our approach to compliance training.
Focus on the positives
The nature of discovering and developing new medicines relies on a strong culture of innovation, so we asked ourselves: ‘Why not use these strengths in the area of compliance and ethics?’ Compliance is a serious subject, but that shouldn’t and needn’t mean that it’s dull or boring. Neither should it be negative, focusing on the ‘fear factor’ of the consequences of non-compliance. Instead, it should foster integrity, values, ethical behaviours and best practice.
As a result, in 2017, we moved from a ‘Code of Conduct’ to a ‘Code of Ethics’ – a change of one word that has made a big difference. We also introduced our Act Right Now values, shifting the perception of compliance from a ‘blocker’ (negative) to an ‘enabler’ (positive). As one learner commented: ‘Those three words mean something when combined – there’s an urgency to act when something isn’t correct – but each and every one means something on its own too.’
Beyond this, we still felt there was scope to take learning to the next level. We sought external expertise to help us challenge conventions and come up with innovative approaches. Working very much in partnership with Sponge, we focused on learning that would empower AstraZeneca employees to use their good judgement to make the right choices in their roles every day, instead of focusing on what would happen if they broke specific rules.
A significant change was to make our Code of Ethics more conceptual so that the audience, regardless of job role, location, culture, experience or device preference, could apply them to a broad range of situations. For example, we used video to deliver key concepts that prompt an emotional response rather than relying too heavily on words or metaphors to convey meaning. As one learner explained, ‘There was not a lot of text…which is good for a global company as it makes it easy for everyone to understand, from production through to senior managers’.
Improved completion rates and effectiveness
Just as DNA contains the genetic instructions for building a life form, learning is the foundation from which our people and the business will grow.
The switch in emphasis from ‘rules’ to ‘principles’ and the move towards positive motivation has transformed the effectiveness of our compliance training, as has the organisation-wide reach of the multi-device delivery. Completion rates were up 13% in 2018 compared to the previous training in 2017 and there was a 21% increase in the number of people who completed the training on day one. Almost a quarter (23%) did the training on mobile devices.
Some 2,226 employees completed a learner feedback survey after completing the training without being prompted – an unprecedented number. The results revealed that 86% said their understanding of AstraZeneca’s values had increased or greatly increased; 94% were likely or very likely to recommend the training and 90% felt ‘very’ or ‘extremely engaged’ with the learning. Furthermore, training was described as ‘interesting’, ‘engaging’ and ‘inspiring’ – words rarely associated with compliance training.
Our Code of Ethics is now firmly in place to encourage independent thinking and decision-making within our core values and principles. Through learning, we trust and empower our employees to make the right, informed decisions, every single day. Compliance that’s embedded – and positive.
For pharmaceuticals to successfully embed ethics in their DNA, we recommend an injection of creativity in compliance training.
Louise Vamvoukaki is associate director, Sustainability, Education and Engagement Lead, at AstraZeneca.
