Thoughts While Shaving…

Compliance Training is Overrated

Fostering a Speak Up Culture Will Carry Your Organization Farther

A version of this article appears in Corporate Compliance Insights

While training is helpful and important, it can get too much focus. After all, training doesn’t address the primary reasons people do what they do. Ronnie Feldman discusses the importance of changing the culture.

Ethics and compliance programs tend to put much of their focus on training – making the training shorter, making it modular, making it interactive, making it more targeted, making it trackable and measurable and so on. This is a good thing, because as we know, not every company tries to make the training (ahem) “tolerably good” for employees, and that conservative approach to training will likely come back to haunt them.

How to make effective training is a whole other discussion in and of itself. What I’d like to focus on is the fact that while great training is helpful and important, it gets far too much focus, because it does not address one of the primary influences of why people do the things they do. Behavior science tells us that knowledge and understanding does not necessarily mean that people will behave according to that knowledge, and that’s because environment has a huge influence on behavior.

“Environment Affects Behavior”

The Fundamental Attribution Error (FAE) essentially says that people tend to overestimate internal stimulus (i.e., “I’m a good person”), and they underestimate external stimulus (i.e., “there are other factors that influence what we do”). We all tend to believe we’re good, and what’s interesting is, we are really good at justifying our bad and/or unhealthy behaviors.

Conformity & Group Think: The desire for conformity results in an irrational or dysfunctional decision-making.

The Solomon Asch study famously tested the power of the social environment on conformity. In the study, the subjects would intentionally provide incorrect answers to questions, knowing it was incorrect, because they didn’t want to go against the crowd. The entertaining clip below from the old TV show “Candid Camera” illustrates the power of social pressure on conformity.

Conformity and Group Think – Candid Camera

The Stanley Milgram study in the 1960s famously showed that subjects (“T” in the image below) tend to obey orders from others whom they deem an authority figure (“E”). In this study, they were instructed to press a button, which, unbeknownst to the subjects, would deliver an electric shock to a third participant (“L”) in an adjacent room. When they did, the person in the adjoining room would scream in pain. The subjects were instructed to keep doing this, even though the screams would get worse. What’s fascinating is that the majority of people reluctantly kept pressing the button, because they were told to, even though they knew it was wrong. Shockingly right!

The point is that smart, well-intentioned, well-informed people will sometimes do the wrong things if the social environment is accepting of it and/or if they feel pressure to do so, even though they have the proper knowledge and understanding. The power of conformity and groupthink is strong and can work against you (i.e., “it’s no big deal, everybody’s doing it,” and “it’s okay, you’ve been working hard and you deserve a break”). Conformity can also work foryou (i.e., “hey, we’re not the kind of company that does that”).

You can have 100 percent completion rates and high knowledge test scores that are improving, but that still doesn’t mean employees trust the ethics and compliance team, trust that leadership supports them and trust the process for those that speak up.

They say culture eats strategy;
well, culture eats training.

You could argue it’s even more important to spend your time and effort establishing a social environment where employees feel comfortable asking questions and speaking up to report concerns. Then, whether they know the right information or not, they feel comfortable seeking out advice. Or better yet, you create a culture where employees are more likely to police themselves. This is hard to do.

You can’t change your culture overnight; however, you can influence it by how you choose to communicate. In fact, I would argue that ethics and compliance (with leadership’s support) is in one of the best positions to actively influence the culture, because you cut across the entire organization. The most important attribute of an ethics and compliance professional is the ability to influence the culture. This requires a sustained and continuous effort:

  • to reinforce your principles and values,
  • to reinforce the importance of speaking up to ask questions and report concerns,
  • to showcase what happens to those that do – and don’t – follow these principles so that employees feel psychologically safe and
  • to do this in a way that’s interesting, positive and colorful (so they don’t tune you out).

Yes, this effort will require improved education and training so that those communication touchpoints are positive and meaningful. But let’s not ignore the ongoing drumbeat of communication and awareness that needs to surround and support those training efforts so that the environment is trusting and supportive and groupthink starts to work to your collective advantage.

Ethics & Compliance Role vs. Reputation: The Great Irony

A version of this article appears in Corporate Compliance Insights.

You are smart. You’ve got a welcoming smile. You have interesting anecdotes. You’re a snappy dresser and a quick wit. And to top it all off, your role in the organization is to provide guidance, advice and support to help employees navigate the workplace within the rules. This is a noble and worthy cause and it comes with a great irony. You are trying to help them and they resent you.

“Ethics” and “Compliance” are loaded words. By the very nature of the name and title, there is a pre-disposition for employees not to engage. Much of this reputation, frankly, has been earned through a history of boring, check-the-box, mind-numbingly awful, required, preachy, legalese policies and training forced down their throats with little regard towards how they might feel about it. Even if that’s a bit harsh and you have evolved your training and communications to be shorter, more empathetic and engaging, employees are continually entering the organization from elsewhere, where they may not have had such a great experience.

The fact is that you are starting from a disadvantage. You are not playing to a “warm room.” Whether its earned or not, you likely have a vaguely bad reputation. There is a fundamental misunderstanding of your teams role and function. And guess what? People don’t speak up to ask questions and report concerns when they are annoyed, apathetic, or afraid. The old saying is, “people won’t go to the office of no.”
This is the primary challenge that ethics and compliance professionals need to solve above all else, before any real success can be achieved. To mitigating risk for your organization, you first have to tackle this reputation problem. This can’t be undone all at once, because it has developed over time. It will require a hard look at all the different ways you and your team train and communicate, and it will require a sustained effort to train and communicate differently over time.

This is where blending entertainment with learning can help, as a way to “rebrand” the ethics and compliance team as a welcoming, helpful, positive resource of advisors and coaches. Being entertaining with your messaging has little to do with being humorous or funny. It has everything to do with being more interesting and approachable and standing out in an environment where it’s difficult to rise above the noise. It’s about creating a social environment where employees feel more comfortable speaking up to ask questions and report concerns. So try new things. Be interesting and provocative. Remind them that you are on their side and you got their back. Speak it loud and proud. And slowly but surely, we’ll change the reputation, increase your influence and create the speak up culture that we all are striving for.

Short, Funny Gifts & Entertainment Training Videos

Short, Funny Gifts & Entertainment Policy Training Videos

Ethics & Compliance Training, Communication & Awareness

Don’t Just Train…Advertise!

It’s that time of year again – gift giving season! Hooray! However, those of you in the ethics, compliance and corporate risk community know that the holiday season brings with it a lot of potential problems for employees.

So, what do you do? You send out a stern reminder email that they delete before reading because it’s from compliance. Or you trot out the rather ominous gift & entertainment policy that was written by a lawyer that makes your brain hurt. Or you post something on the intranet site that no one ever visits. Or you push out a training video highlighting a relevant scenario, but the acting is really bad and it’s a little condescending and secretly employees hate you for it. Boring, boring and more boring…and easily ignored and forgotten. But, if not that, than what?

Here’s a workplace fact. Most employees don’t think about this issue at all, which is in and of itself a problem. But if they do, here is what they are thinking.

  • What kind of gifts can I give and to whom?
  • What kind of gifts can I receive and what do I do when I receive one?
  • What the hell is nominal value?
  • What’s the big deal anyway?
  • What will happen if someone finds out?
  • Who do I contact to find out more info and where is that information?

Here’s another workplace fact. Most employees are people! And human beings, as mischievous as we are, generally like to stay out of trouble with the people that pay them. Many want to achieve and most want to be a good person, but ALL want to avoid the hassle of doing something that will get them in trouble. They just want a simple way to get the info they need.

Here’s another workplace fact. People are forgetful. We all have short-term working memory, which means that we know a lot of stuff, but it’s not always available to us in the time of need. There is an old truism that I think makes sense here and that is “people need to be reminded more often then instructed” which is attributed to Samuel Johnson. I’m not going to tell you about him. He has a white wig on which makes him seem important. You can Google it and look him up on your own time.

So, if people are forgetful and have short-term working memories, they don’t need more training. They need more reminders so the information is top-of-mind in the time of need. If they generally want to avoid causing problems, then they simply need to recognize that there is a potential issue and they know where to go for more information. This can be solved through advertising, i.e. a series of simple, short, interesting “commercials” that appear in lots of places, gives them a simple message that they can remember, and tells them where to go for more information. One more thing. If you want to remind more often, then you will be more successful if your messaging is entertaining and fun. It doesn’t have to be funny or humorous or comedic, although that is helpful. It does, however need to be interesting and memorable. Then you can run that commercial more often and it further solidifies the message.

Here is one example of short, fun, catchy, 60-second Gifts & Entertainment jingle. Click on picture or link below.

Short, Funny Gifts & Entertainment Policy Training Videos

When it comes to ethics, compliance, privacy, information security,  workplace behavior and the Code of Conduct, we spend way too much time force-feeding bad, condescending, finger-waggy training down peoples’ throats and it works against our interests. Employees just tune out. Train less. Advertise more in short, interesting, positive ways. Focus on three simple things.

  1. Remind them of an issue/topic with one simple message.
  2. Tell them where to go for more info.
  3. Let them know that it’s safe to go there.

This advertising-like approach will give you a better chance of having a well informed audience and in addition helps create an environment of trust and support.

———-   ———-

L&E has a large library of short, entertaining, commercials in a variety of fun formats and styles addressing common corporate risk areas, including:

  • Gifts & Entertainment Policy
  • Conflicts of Interest
  • Helpline & Hotline promotion
  • Speak up and confidential reporting
  • Integrity & Workplace Respect
  • Privacy, Confidentiality & Information Security
  • Harassment & Discrimination
  • And more

Contact us at to discuss how we can customize these or create new materials to meet your specific training and communication needs.

Why Humor is Serious Business For Cyber Security & Compliance

In improv comedy circles there is a saying. “Things are funny because they are true.” This doesn’t mean that all things funny are true. It means that comedy tends to work when it is based on some truth. This is an effective formula for the satirical late night talk/news shows (The Daily Show, John Oliver Show, Stephen Colbert, etc.) that are trying to shed light on hypocrisy in the world and it’s also a great formula for corporate educators who are trying to raise and maintain awareness about important corporate messaging. It’s an effective tool to accentuate some shared truth and to get people to see an issue or point of view in a fresh new way.

This is particularly important when your product or service is boring, scary or complex. Hellooo information security and compliance! It may seem counter-intuitive, but the more serious and complex the issue, the more effective entertainment can be as a tool for communication, education and employee engagement. In fact, these approaches are now being encouraged.

“Both the US Sentencing Guidelines and recent USDOJ guidance suggest that organizations must not only provide informal communication on risk topics but must do so in a form that is effective for the audience.” -Eric Morehead, Principal, Morehead Compliance Consulting

Despite this, companies still seem reticent to try new, creative approaches. Information security and compliance professionals often think that because of the serious consequences surrounding these issues, the topics needs to be addressed in a serious tone. This conservative thinking, when it comes to training, communicating and engaging employees, actually puts the organization at risk. Why? Because employees aren’t paying attention and learning.

I happen to run a creative shop that’s built on blending entertainment with learning and I’ve spent over 20+ years experimenting with fun, new ways to get people to pay attention, engage and remember boring, complex, often difficult issues. I find myself having the same conversations every day, which is why I’m writing this piece. These are the things I tend to hear.

Entertainment In Service of a Message

First off, entertainment doesn’t necessarily mean comedy and in this context, it certainly doesn’t mean “to make fun of.” That is a misnomer. Entertainment, based on truth, is simply an effective vehicle to get employees to listen. It’s a great way to hold a mirror up to what’s really happening. It’s a way to show empathy. And it’s a way to build trust.

“These issues are so important…we need to make sure our employees pay attention and remember.”

Data Privacy, Corruption, Conflicts, Antitrust, Harassment, Reporting, Phishing are all weighty, complicated issues. But remember…there is a difference between having a difficult conversation and a conversation about a difficult thing. It is perfectly acceptable and quite frankly more effective, to separate the substance of the message, from the delivery mechanism.

There are a variety of entertaining approaches that can be utilized in service of your messaging. For examples, just take a look at the way people consume information in their everyday lives. There are sitcoms, music videos, investigative reporter shows, movies and movie trailers, game shows, and infomercials. We listen to the radio and podcasts. Our eyes are drawn to GIF’s and Memes and graphics on social media channels. All of these devices can be utilized to tee up an important message in a format that people are comfortable with and will pay attention to. And these approaches tend to stand out even more in sterilized conservative corporate environments where the new beige is considered exciting. Remember, people are business people some of the time and regular people-people all of the time!

Advertisers have known this for years. Most products are boring. But most commercials are entertaining. What’s exciting about insurance or a new soda bottle design? What the hell is drinkability? Why am I still humming that carpet commercial I heard on the radio this morning.

I have no idea..but I remember it! This is the point. If you want employees to know that your ethics hotline is available for reporting workplace concerns, you can send them the policy and make them certify that they have read and understood it. Or you can write a song about it and have it stuck in their heads. Airline safety videos are the perfect parallel for successfully using entertainment to highlight a serious issues that people have been tuning out for years. They aren’t making fun of safety…they are using entertainment to ensure that you pay attention, engage and remember.

It’s Not About The Funny

It’s important to note that it’s not about the funny. These approaches are about breaking down barriers, opening up conversations, making emotional connections and winning hearts and minds. There is a halo effect. It can make these complex issues and you and your team, less scary and more accessible. If you show empathy for your audience, it helps build trust.

“In info security, we’re not always the greatest communicators. We often talk in techno-babble. We’re the office of “no.” People tune us out. Having some fun materials in our bag helps us to simplify our message and communicate more effectively.” – Chief Information Security Officer, Global Technology Organization

I’m No Longer The Scary Compliance Professional

“…people now stop us in the hallway and talk to us! Some tell me how much they appreciate the effort. Others tell me that they didn’t like a particular video very much. But these interactions themselves are invaluable because we’re getting to know each other and are building trust. They know that I care enough to try and make it interesting. I’m no longer the scary compliance professional.” -Compliance Director, Global Pharmaceutical Company

Is It Okay If We Laugh?

“I thought we were running a pretty successful compliance program and I was unsure about the idea of introducing humor, but my team really thought it was a good idea. So at my next big presentation, I was in front of 500 employees and I thought I’d give it a try. I played one of the shorts and absolutely no one laughed! They just stared at me and I was embarrassed. Then a person raised their hand and sheepishly asked, “Is it okay if we laugh?” I said, “of course!” and the room erupted! And in that moment I knew that we had a problem. There was so much angst and tension in the room that they weren’t engaged. Therein lies the value…to get employees to pay attention and listen.” Chief Ethics & Compliance Officer, Fortune 100 Insurance Company

Science and Memory

  • Emotional Connections: Humor, music and other entertaining content tends to make emotional connections with people.
  • Retention: Humor, music and other entertaining content tends to have a higher content retention rate. People remember things that are provocative, interesting and fun!

Employees will likely forget most of your PowerPoint presentation and your E-learning module with the voice over and bad stock photography. They will remember the fun song and the humorous video. That will stick with them. The most effective education is a blend of both emotional and cognitive approaches. When giving them the medicine, don’t forget to mix in a little sugar.

Conservative Approaches Put The Organization At Risk

Most corporate training and communications tends to scrub out all that’s interesting and fun. This is the unintentional consequence of the process which takes great pains not to offend and tries to ensure that the organization communicates in a way that all levels of the organization can comprehend. These are important considerations. But by the time a training, newsletter, intranet policy portal or corporate communication has gone through all the checks and approvals, it may have all the correct punctuation and some great information, but it’s just plain boring. And this puts your organization at risk…because no one is reading the newsletter. No one remembers the policy. No one cares about the issue. This conservative approach is what creates the conservative culture which leads to a culture of apathy and complacency. We need to raise the bar and choose to communicate like humans.

One of my favorite quotes is from the legendary improv guru, Del Close, who was a bit insane but spouted much wisdom.

“Treat your audience like artists, poets and geniuses and they have the chance to become them” – Del Close

Can You Measure That, Please?

“We were rolling out a new Code of Business Conduct and decided to use a comedic approach showing how the Code changed throughout our companies history. We had it translated into 15 languages and spent a lot of time and care rolling out a campaign to generate some buzz. We also measured the results which presented some interesting findings. We received an 88% positive response rate…Good news! However, we also received a 6% negative response rate and 6% were neutral. We have 50,000 employees so that’s about 3,000 people who really disliked it. That’s a lot of people! We decided to take the initiative to reach out to those 3,000 people to engage them in a discussion about their concerns. This took some time, but in the end, we were able to use the negative responses as teaching moments about compliance. Ultimately, we think its important to try and get a pulse out of people, positive or negative. You won’t engage the masses by being dull. Anything is better than apathy.” -Director of Ethics & Compliance, Global Technology Company

Employee Engagement – Variety is the Spice of Life – Try New Things!

There is a solid business case for using entertainment as a vehicle for raising and maintaining awareness around policies and corporate risk. If you continue to push out beige, you will engage absolutely no one. That’s risky.

I think it’s important to be thoughtful about the styles and formats you use to engage employees, but don’t get hung up on creating the perfect thing. There is no one single way to engage a multicultural, multigenerational, diverse workforce. I encourage you to try lots of different creative approaches and a variety of different entertaining formats and styles. There is no need to put all your eggs in one basket. Some will work better than others. But it’s important to try new things. You will be most successful through variety and surprise, which gives you the best chance of engaging the most people over time. It also shows that you care enough to make it interesting for them, which goes a long way toward building trust. Entertainment and learning is not about the funny, it’s all about breaking down barriers, opening up conversations, making emotional connections and winning hearts and minds. It’s not only more fun, it’s more effective.


Ronnie Feldman is President & Creative Director of Learnings & Entertainments, a network of comedians, musicians, writers, and production crew that focus on employee engagement, communication and corporate education. *

Security Awareness – Don’t Just Train…Advertise!

Information Security Awareness is an Everyday Activity…An Advertising Approach Can Help!

It’s well known that the human factor accounts for the vast majority of information security incidents. So, in addition to all the dollars being spent on technology solutions, companies typically spend the majority of their efforts on training, tracking and measurement. I get that the 100% completion rate serves a purpose, but the majority of training deployed is tedious and preachy and isn’t actually educating anyone. In fact, it often leads the employee feeling resentful. They’ll forget the lesson and remember how you and your department made them feel! If the goal is to win employee mindshare, change behaviors and mitigate risk, an advertising approach can help. This is because of a very important, sophisticated scientific principle:


FREQUENCY MATTERS: Smart, intelligent people still screw up. That’s in part because knowledge and understanding is only part of the equation. This is why even great, fun, interactive training doesn’t get at the root of the issue. Advertisers use the term “Effective Frequency” to refer to the number of times a person has to see something before taking action. Annual training and quarterly push campaigns aren’t enough because the relevant info will not be top of mind at the time of need. If you want to integrate your messaging into the culture, you need a regular cadence of simple, positive, interesting communications. This means more than just monthly newsletters. It means finding ways to show up where employees already are and that means, working with other departments to get them to integrate your messaging within the business. Regular vitamins are more effective than training inoculations. Strive to make your messaging ubiquitous. Here’s why.

  • Short Attention Spans: Now 7 seconds…shorter than a goldfish.
  • The Forgetting Curve is Steep. 87% of corporate learning is lost within the first month.
  • Limited Working Memory: This is the temporary storing of information for reasoning and decision making. You need to have messaging top of mind when the situation for needing that info occurs.


Upping your frequency is a great start. However, if your messaging is dull and boring, you may not get the results you are looking for. They will tune you out! That’s because:

INTERESTING MATTERS:  Cyber security programs need to start taking advantage of the many company communication channels available, but to get “air time” you need to have something fresh and interesting to share. Nobody likes the finger-wag. A regular stream of short, preachy communications can lead to message fatigue and resentment. Boring messages will go unnoticed and will be quickly forgotten. We know that frequency matters, but its also important to communicate in interesting ways. It’s not about being funny…it’s about standing out and getting attention, bridging connections, being memorable and winning them over. More communication channels will become available to you if you have something interesting to share. Get creative. Be interesting!

  • Emotional Connections & Retention: Music & humor makes emotional connections and tends to have a higher content retention rate.
  • Breaks Down Barriers / Builds Bridges: Laughter comes from shared recognition and makes tough-to-get-at topics more accessible. Humor is a great technique to highlight and comment on things that are true. It’s great for opening up conversations, bridging alignment and building trust.
  • Some Examples: The Fun Theory Airline Safety Videos



DON’T JUST TRAIN…ADVERTISE! – People forget stuff. Knowledge and understanding is only part of the equation. You need to have messaging top of mind when the situation for needing that info occurs. That can be solved by communicating more frequently.

SHOW UP IN MORE PLACES – Partner with your business colleagues to integrate your messaging within their communication channels. Place messaging where employees already are – other department newsletters and websites, screen savers, video message boards, social collaboration sites like Yammer, Jive or Slack, high-traffic areas (bathrooms, whiteboards, break rooms), sales meetings agendas and pre-meeting slides, webinar/conference call waiting rooms, leave voicemails, etc. Get creative. Communicate frequently to have a more consistent positive presence and increase the likelihood the the messages will be top of mind when problems occur.

COMMUNICATE DIFFERENTLY – Complex, scary topics can be inaccessible. People’s eyes gloss over. Look for opportunities to communicate differently…positively and in entertaining ways. Take a look at how your policies are written, the tone of your training, what your intranet site looks like, how your emails are written, and how you talk to people. Spend the extra time to make you, your policies and your program more accessible.  People won’t go to the office of “no.”

KEEP IT SIMPLE – Employees are busy, have short attention spans and limited working memory. Keep messaging simple. They won’t remember everything, so focus on giving them simple tips on what to do, tell them where to go for more info and let them know that it’s okay to ask for help. Think of your messaging as an advertisement so they get the idea but know where to go for more info.


Contact L&E to view our library of short, entertaining employee engagement and awareness communications. Over 150 “commercials” that engage employees in 75 seconds or less.

* * * 872.302.7529

Comedians Launch Privacy & Info Security Employee Awareness Communication Campaign

CHICAGO, April 26, 2017 – L&E, a network of comedians, musicians and writers who focus on employee engagement, communication and corporate education, has launched their newest subscription library, the L&E Privacy & Info Security Suites, to help companies raise and maintain employee awareness about the risks associated with this increasingly troublesome topic. The Suites are a large collection of short, fun communications and micro-learnings that act as commercials: songs & jingles, video shorts & animations, memes & GIFs, that surround, support and socialize learning to engage employees in 10-60 seconds.Request a preview of these catchy, musical shorts at

“Anyone who watches TV, listens to the radio or surfs online is familiar with advertisers embedding short, catchy commercials to promote their services. We’re approaching this risk area the same way by providing companies with a customizable toolkit of social media style assets that can be pushed out periodically or integrated into the fabric of the organization, like advertising, to raise and maintain awareness all year long. We want to enable cyber security teams to have a presence wherever employees already are with messaging that is simple, positive, interesting and memorable,” says Ronnie Feldman, president of L&E.


“We use the L&E shorts as entertaining advertisements – on screensavers, on newsletters, on departmental websites, on video message boards, in conference call waiting rooms – to not only deliver quick reminders and reinforcements, but also to drive traffic back to tips, tools and resources that can often be ignored. This fun and entertaining method of security awareness helps us get more value out of the resources we’ve already invested in,” says Marc French, CISO, Constant Contact.


“We believe security awareness is extremely important and needs to be kept at the forefront of our employees’ minds. L&E’s creative approach helps us stay engaged with our teams through brief, but memorable trainings that are a great complement to our broader security awareness program,” says Doug Graham, Chief Security Officer, Nuance Communications.


“L&E has brought a lot of fresh, fun ideas,” says Bob Trovato, Manager Information Security, Progressive Insurance. “We can now capture a wider range of audiences quickly, with a consistent message, and have fun doing it.”

The Suites were created in collaboration with privacy and data security professionals from Constant Contact, Nuance Communications and Progressive Insurance. The Suites cover topics including phishing, cloud usage, careful communication, securing devices and surroundings, working remotely, password sharing, social media risk and more.

For more information, go to