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Beyond ‘Checking the Box’: Cultivating a Culture of Compliance

by | May 18, 2021

Culture of ComplianceUsing cliffhangers, compelling storylines, and multidimensional characters, Rashelle Tanner reimagined Microsoft’s Standards of Conduct compliance training course as a series of episodic dramas. The resulting award-winning course, which is required learning for over 142,000 Microsoft employees, is wildly popular. Among the many course-related tweets, one said the “standards of business conduct training this year feels like a new James Bond movie.” 

We spoke with Tanner, who received her JD from Seattle University School of Law, to learn more about this and other innovative approaches to compliance. Tanner is the director of integrity and compliance learning and senior corporate counsel at Microsoft. Also, she is a faculty member in Seattle U Law’s Master of Legal Studies in Compliance and Risk Management program.

Culture of Compliance, Placing Values at the Forefront of Compliance

Rashelle Tanner began the conversation by discussing the primacy of values in considering how to approach compliance. “I tell people to step back and not think of compliance only as a set of rules or regulations that employees must do,” she said, “but instead to view compliance as who an organization is and what the organization has to offer.” “What is the culture that we can build to have a compliance-minded team?” 

For the Standards of Business Conduct course, Tanner said the underlying message is that her global organization runs on trust. The course shows the organization’s values through the universal art of storytelling, and it focuses on those values rather than rules. Tanner said: “When characters in the course approach ethical decisions in their day-to-day job, the characters may not have every rule memorized, but they have the awareness to know that something is off or that they may need to ask for guidance. In the same way, the course aims to develop awareness about the values that should guide employee behavior.” 

“Imagine you’re sitting at your desk with a bunch of privacy rules about what you can and cannot do,” Tanner explained. You may tell yourself you need to remember the information, she told us, but you may not internalize the information. On the other hand, if your company has strong values and compliance is tied to those values, then compliance becomes part of the regular workings of the organization. “We want to make sure that we’re building trust with our customers, with government agencies, and with each other,” said Tanner. “We keep that at the core of everything we do.” This is a key piece in cultivating a culture of compliance.

Making Compliance Engaging and Relevant

Tanner designed the course as a series of episodes with complex fictional characters and compelling storylines, including cliffhangers that build suspense. “It’s a Netflix-type episodic drama,” she said. “Typically every corporation requires employees to complete a course about standards of business conduct each year. We do that too, but ours is delivered in episodes that release each season.”

Sometimes people respond to the idea of compliance training or learning dismissively, as a check-the-box item, said Tanner, “but opportunities exist within compliance to make a difference and do things differently.” “The Standards of Business Conduct course at Microsoft is well received. Opportunities exist to design creative, engaging, and impactful learning.” 

“The best learning–and I call it learning instead of training,” Tanner explained, “is tailored for its audience and relevant to what they do, with immediate application.” Good learning compels the audience to engage with it. If the scenarios in a training course are too predictable, she explained, learners may fail to engage with the course because the material is unrealistic. 

“Real life,” Tanner said, “can be messy, with shades of gray.” “People don’t appear with a suitcase full of money, trying to bribe someone, as might be presented in a more typical training course. In real life, the issues are less obvious.” 

Employee Engagement (Even Tweets about the Characters!)

“What we try to do in the course,” Tanner explained, “is create multi-dimensional characters that employees root for and engage with.” Employees tweet about the characters. Outside of the context of the course, employees engage organically in conversations about the fictional characters because the storylines are gripping and resonate with employees. This, says Tanner, is useful because it inserts compliance into the daily fabric of the organization. 

“One of the reasons I believe employees engage so readily with the course is that we make it very relevant and very current to what we’re doing at Microsoft.” In season four, Tanner hired a production company to film scenes at the Microsoft office in Beijing. “We’re a global organization,” she explained, and the course needs to reflect that.

“The idea is to understand what you want your workforce to do; to know how employee behavior affects the bottom line, the business, and the culture; and to be able to bring information to employees in less traditional ways. We avoided creating a typical learning course and instead engaged our people differently, and it has been a great experience.”

Master of Legal Studies in Compliance and Risk Management Program

Our conversation with Professor Tanner covered a range of additional topics, including how to build accountability and opportunities for innovation in the compliance and risk management landscape. Also, the webinar discussed how Seattle U Law’s Master of Legal Studies in Compliance and Risk Management program helps individuals who want to advance their careers and learn from respected leaders in ethics, compliance, and risk management. 

Depending on professional goals and interests, students in the fully online program can optionally choose to focus on the following concentrations.

The MLS program provides opportunities to solve problems through a legal lens and gain foundational knowledge of the law, but without a JD. It prepares graduates to lead compliance efforts in any organization, regardless of industry. Students graduate with a commanding knowledge of the law, legal analysis, and the frameworks used to identify, assess, and respond to risk. The program’s values-based approach moves beyond a narrow sense of compliance and helps establish a sense of equity, justice, and inclusion.

To learn more about the program and our conversation with Professor Tanner, you can view the full webinar recording or contact us at lawgraduateonline@seattleu.edu.