AIB is Ireland's largest banking and financial services company with $13B market capitalization and a significant retail presence in UK and Poland, as well as investments in the USA global and capital markets. A compliance and ethics training program (COMeT) is being delivered to all 25,000 AIB employees using E-learning. SAI Global is the leading partner working with AIB to provide cost-effective enterprise-wide training. The program enables AIB to proactively respond to complex regulatory changes while maintaining and promoting a business context and standards. The current program is predominantly provided by SAI Global and consists of modules covering an Introduction to Compliance, Anti-money laundering, Complaints Management, Preventing Mis-selling of Products and Services and Conflicts of Interest.
One of the biggest challenges and therefore one of the major objectives we faced was to break down the complexity of compliance by bringing focus and clarity to a very complicated issue
Lorraine Duffy
AIB business ethics & policy manager
Like many banks, AIB finds the complexity of regulatory changes such as the recent Third EU Money-Laundering Directive, very challenging. Selling thousands of products across a number of markets poses its own compliance risks, particularly in relation to anti-money laundering and conflicts of interest. Another key consideration is the risk of ethical breaches in relation to code of conduct and industry standards such as Sarbanes Oxley.
As an international operator, AIB also has to factor into any training and awareness programs cross-border differences in language, culture and infrastructure. "But with the help of SAI Global we also identified cultural differences between business divisions in the same country," comments Lorraine. "This helped us to conquer one of the biggest challenges which was to develop a financially viable program, where 80 per cent of the content needed to be common to all audiences, without sacrificing local business needs."
Focusing on the necessary behaviors required is often overlooked in traditional training programs, which have a tendency to focus on rules and procedures. AIB has tackled this on a number of levels. "Firstly there's a need to have clear compliance procedures and ethical standards. Secondly, the ability to monitor and report is crucial for consistent, strong enforcement and effective evaluation.
Finally, procedures regarding acceptable behavior need to be well communicated and coordinated," explains Lorraine.
The challenge comes when there is no written procedure and the staff member needs to know the right thing to do and its potential impact. Staff want to do the best for the company as well as being true to their own personal values. Our strategy in COMeT training aims to give staff the confidence, knowledge and framework to 'do the right thing' even when it isn't possible to refer to a written instruction.
Lorraine Duffy
Ethics and Compliance must be managed in a holistic way. AIB achieves this through clear and visible leadership from the top based on stated ethical values, which are supported by policy, training and awareness and on-going monitoring, evaluation and investigation.
The role of Compliance was traditionally seen by staff as that of a policeman. "We needed to engage with the business in changing this mindset by designing solutions with a fresh and innovative approach that focused on the individual user, the business, its customers and all other stakeholders. We needed to simplify complex procedures using visual interpretation to help staff engage and remember critical learning points," observes Lorraine.
"By making the training relevant to the individual, this challenged them to consider how they'd respond to a particular situation. There is a strong appetite for scenario-based training, supported by decision based models to deal with everyday dilemmas - essentially it is training not through 'telling' but by experience through examples."
"We can clearly demonstrate a positive shift in knowledge - the benefits of which are invaluable to AIB," explains Lorraine. In addition, in many cases the average pass rate at end of course assessments is higher than best Best Practice Learning standards. So far, 95 per cent of staff have been through the compliance training program, passing first time in most cases with others taking no more than two attempts to pass. The satisfaction rate stands at 91 per cent when measuring reaction to design, engagement levels etc. A significant growth in understanding of the subject before/after training is also noted. The modules have also been accredited externally with The Institute of Bankers in Ireland, The Warsaw Institute of Banking and endorsed by the Institute of Financial Services (ifs) in the UK.
Undertaking a complex international compliance awareness program is not without its trials and tribulations. "As an organization, AIB has gone through a significant learning curve, implementing an enterprise-wide eLearning program using a single IT platform. eLearning design and delivery is heavily dependent on your IT build, from your PC, bandwidth and LMS. This required rigorous eLearning design standards and technical support, in which SAI Global's expertise proved invaluable. However, with the fast pace of IT, you cannot become complacent and you must continuously revise your design standards," says Lorraine. "AIB wanted a high quality and professional eLearning compliance and ethics program and the fact that we have limited bandwidth with many concurrent users in many of our locations provided a real challenge to us and our suppliers. This was overcome with strong technical advice and project management from SAI Global who also worked with us in the development of our enterprise technical content standards at an early stage of the program's development".
"Employees like e-learning but this brings with it the risk of wanting to do all training this way. However there is still a place for classroom training," concludes Lorraine, "eLearning is perfect for technical and standards training, where consistent communication is important and where it is possible for delegates to learn in a 'safe' environment and where they don't have to voice their answers to a group. But there are areas where learning could benefit from an open debate and exchange of shared experiences between delegates. Overall I still believe a blended approach to learning is the most effective. Employees are able to 'do the right thing' rather than being told what to do, through understanding corporate values and aligning these to their own personal values."
AIB Group is Ireland's leading banking and financial services organization. It operates principally in Ireland, Britain, Poland and the USA. It has global corporate and capital markets operations. It employs more than 24,000 people worldwide in more than 750 offices.
SAI Global is one of the world's leading information services, compliance, training and assurance organizations with operations in Europe, North America, and Asia Pacific.
What is COMeT?
The Compliance and Ethics training program through e-Learning (COMeT) is a strategic, integrated Enterprise compliance and ethics training program. COMeT consists of six fully customized courses dealing with a range of compliance and ethics topics. All staff will take these courses annually. COMeT is accredited and certified by Institute of Bankers in Ireland, Warsaw Institute of Banking and endorsed by ifs (Institute of Financial Studies) in UK. The courses were developed in partnership with the business and include the local regulatory and business requirements and are supported by classroom training to ensure a holistic and blended approach to compliance and ethics training.