Annotated bibliography

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Journal of Business Ethics (2020) 162:835–855 https://doi.org/10.1007/s10551-019-04364-9

O R I G I N A L PA P E R

From Preaching to Behavioral Change: Fostering Ethics and Compliance Learning in the Workplace

Christian Hauser1

Received: 4 April 2018 / Accepted: 13 November 2019 / Published online: 28 November 2019 © Springer Nature B.V. 2019

Abstract Despite the increasing inclusion of ethics and compliance issues in corporate training, the business world remains rife with breaches of responsible management conduct. This situation indicates a knowledge–practice gap among professionals, i.e., a discrepancy between their knowledge of responsible management principles and their behavior in day-to-day business life. With this in mind, this paper addresses the formative, developmental question of how companies’ ethics and compliance training programs should be organized in a manner that enhances their potential to be effective. Drawing on both the quali- tative analysis of existing ethics and compliance training and the conceptual literature on behavioral ethics, a framework is proposed that consecutively aligns various types of training into a comprehensive ethics and compliance training program. The strengths and limitations of the suggested framework are discussed.

Keywords Business ethics · Responsible management learning · Ethics training · Employee training · Ethical employee behavior · Compliance

JEL Classification A13 · D73 · K4 · L2 · M14 · M53

Introduction

In recent years, an increasing number of companies have been training their executives and employees in the field of ethics and compliance (Weber and Wasieleski 2013; Weber 2015). In particular, companies that have previously

experienced corrupt practices are recognizing the need to integrate responsible management principles into their cor- porate training activities (Hauser and Hogenacker 2014). The sentencing guidelines of the US Foreign Corrupt Prac- tices Act create a further incentive for companies to intro- duce ethics and compliance training; such programs can help mitigate fines or even result in deferred prosecution (Kaplan and Walker 2008; United States Sentencing Com- mission 2016). Moreover, the OECD Anti-Bribery Conven- tion procedure, according to which signatories perform peer review of countries’ anti-corruption performance, provides a governance structure to further promote the implementation of ethics and compliance training programs in companies domiciled in OECD countries (OECD 2010). Furthermore, multistakeholder initiatives such as the United Nations Global Compact encourage companies to implement such training programs (UN Global Compact 2009). The aim of these training programs is to enable practicing professionals to lead and act responsibly and to avoid getting involved in corrupt business practices (Gentile 2013; Nonet et al. 2016).

Despite the increasing inclusion of ethics and compli- ance issues in corporate training, empirical research into the effectiveness of said training is still in its infancy and

Christian Hauser is Professor of Business Economics and International Management at the University of Applied Sciences of the Grisons and Fellow at the Digital Society Initiative of the University of Zurich, Switzerland. He is a member of the topical platform Ethics of the Swiss Academy of Engineering Sciences (SATW), member of the United Nations Principles for Responsible Management Education (PRME) Working Group on Anti- Corruption and head of the first PRME Business Integrity Action Center in Europe. His research interests include international entrepreneurship, SME and private sector development, corporate responsibility and business integrity.

* Christian Hauser [email protected] www.fhgr.ch/en_integrity

1 PRME Business Integrity Action Center, University of Applied Sciences of the Grisons, Comercialstrasse 22, 7000 Chur, Switzerland

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yields varying results (Maesschalck and de Schrijver 2016). Some empirical works, such as those by Delaney and Sockell (1992), West and Berman (2004), Valentine and Fleischman (2004), Verma et al. (2016), Remišová et al. (2018), and Hauser (2019a), conclude that ethics and compliance train- ing is positively linked to the respective intended outcome under scrutiny. Conversely, other studies, including those by Ritter (2006), Mayhew and Murphy (2009), van Montfort et al. (2013), Warren et al. (2014), and Jonson et al. (2016), find that their research does not conform to the aforemen- tioned correlation due to inconclusive findings.

Furthermore, despite the increasing number of companies implementing ethics and compliance training, the corporate world continues to be rife with breaches of responsible man- agement conduct, ethical failures and scandals (Hauser and Kronthaler 2013; Schembera and Scherer 2017). This situa- tion indicates a knowledge–practice gap among profession- als, meaning that discrepancies might exist between profes- sionals’ knowledge of responsible management principles and their behavior in day-to-day business life (Hibbert and Cunliffe 2015; Nonet et al. 2016). In this context, the find- ings of behavioral ethics research suggest that incorporating the principles of responsible management into training does not automatically lead to behavioral change among practic- ing professionals because cognitive growth alone does not produce the ability and readiness to act responsibly at work (Fiol and Lyles 1985; Hibbert and Cunliffe 2015). Against this background, the aim of the present paper is to propose a multidimensional conceptual framework for how companies’ ethics and compliance training programs should be organ- ized in a manner that enhances their potential to effectively trigger behavior in accordance with the principles of respon- sible management. To this end, the developed framework integrates various training approaches and the different role profiles of instructors, arranging them in a consecutive order whereby the training progresses from more content-oriented and instructor-centered training methods to a practice-ori- ented and trainee-centered style, with each training stage building upon what executives and employees learned in an earlier stage.

The outline of the present paper is as follows: following this introduction, the next section briefly summarizes the relevant literature on responsible management learning, eth- ics and compliance training, and behavioral ethics as well as pedagogical approaches and role profiles of instructors. The subsequent sections explain the methodology and present the results of the qualitative data analysis. Building on the extant literature and the qualitative findings, a multidimensional conceptual framework will be developed, indicating how various types of training and the roles of instructors should be integrated into a comprehensive ethics and compliance training program. Finally, the strengths and limitations of the

proposed framework are discussed, and concluding remarks are made.

Literature Review

Responsible Management Learning

Against the background of a series of prominent corporate scandals that have attracted attention in recent years, com- panies are increasingly acknowledging the importance of responsible business practices to increase their legitimacy and their subsequent chances of survival (Antonacopoulou and Sheaffer 2014; Wesselink et al. 2015). In contempo- rary research, this development has been accompanied by a growing debate about responsible management and its enactment in day-to-day business life (e.g., Abrams 1951; Hilliard 2013; Ennals 2014; Laasch and Conaway 2015; Nonet et al. 2016). Originating in the academic debate on the United Nations Principles for Responsible Management Education (PRME), responsible management education and learning are an expanding and evolving academic endeavor in the field of management studies. These efforts have a central focus on education and learning related to environ- mental sustainability, social responsibility, and ethics-and- compliance-related issues (Laasch and Moosmayer 2015). Responsible management education and learning take place either in an academic context or at work, respectively. In the case of education, students—as future professionals—learn about responsible management through both explicit univer- sity education and implicit ‘hidden’ curricula (Waples et al. 2009; Blasco 2012; Becker et al. 2013; Borges et al. 2017; Goodpaster et al. 2018; Hauser 2019b). In the case of learn- ing, both practicing executives and employees (Verkerk et al. 2001) learn about responsible management in the workplace. Here, learning can occur in formal spaces, such as explicit training programs, and also arises from more implicit social- ization processes (Antonacopoulou and Pesqueux 2010; Verma et al. 2016).

To date, despite the increasing magnitude of studies on the topic of responsible management education in the aca- demic context, relatively little is known about on-the-job learning among practicing executives and employees (Benn et al. 2013). This lacuna is emphasized by the present lack of research on responsible management learning in the work- place. According to Laasch (2018), as of early 2017, 73 aca- demic articles had an explicit focus on responsible manage- ment education, and only one on responsible management learning. Against this background, the present paper aims to address the research gap regarding responsible management learning at work by focusing on explicit training programs implemented by companies, with a particular focus on one

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of the three main areas of responsible management learning: ethics and compliance learning.

Ethics and Compliance Learning in the Workplace

Regular staff training is seen as an essential tool to deter illegal and unethical behavior in organizations (Hauser and Hogenacker 2014; Schembera and Scherer 2017; Hauser 2019a). Effective training should establish executive and employee knowledge and understanding regarding the eth- ics and compliance policies of the company and also raise awareness of the employer’s expectations of compliance with such policies, thus leading employees to behave in an appropriate manner. Hence, ethics and compliance train- ing should, in theory, help minimize the risk of companies becoming involved in undue business practices (Adam and Rachman-Moore 2004; Bryane 2005).

Limitations of Current Ethics and Compliance Training

Regarding the existing training programs of companies, Gentile (2013) identifies five major barriers to ethics and compliance learning in the workplace, including time, relevance, consistency, source, and impact. First, Gentile observes that a prime deterrent to successful implementa- tion of ethics and compliance training is time. The author notes that enterprises usually dedicate only very limited time to training their executives and employees in this field. At the same time, executives and employees often feel that the time spent on ethics and compliance training is wasted, as they seldom see any relevance of such training to their work- ing lives; in fact, they view it as merely a futile and hypo- critical exercise. This attitude is due to the often-observed lack of consistency between how employees are instructed to behave in training and the messages they receive in day- to-day business life. In training, executives and employees are taught that they should, under all circumstances, adhere to legal and ethical standards, yet in practice, they are often under pressure from the company to maximize short-term economic gains, which causes them to behave in a manner opposite to what was taught. Furthermore, the legitimacy of the source delivering the training is essential to its effective- ness. Regarding training suppliers, although external instruc- tors may have substantial knowledge of and experience with the topic, they frequently lack the credibility and authentic- ity required to be effective within the company. Conversely, internal instructors may have strong credibility within the company because they are familiar with its workings, yet, they may not be dedicated, or they might not be experienced facilitators of ethics and compliance conversations. Regard- less of their affiliation with the company, ethics and compli- ance instructors often have little regular contact with execu- tives and employees and thus lack an intimate understanding

of the needs and pressures faced in day-to-day business life. For this reason, messages from superiors and peers, whether implicit or explicit, often trump those given by instructors. Finally, according to Gentile (2013), it is rather demanding to assess the outcomes of ethics and compliance training. Thus, instead of measuring the impact of the training on their executives and employees, companies normally quan- tify the inputs, such as the number of attendees, training hours or enjoyableness based on an end-of-training survey. Consequently, the impacts of ethics and compliance training often remain unclear. These identified limitations thus raise the question of how ethics and compliance learning should be refined (Scriven 1991; Patton 1996) to encourage prac- ticing professionals to acquire and develop awareness and usable knowledge on responsible business conduct as well as act accordingly when confronted with an ethical challenge.

Insights from Behavioral Ethics

Ethics and compliance training is a safe haven, but day-to- day work life is unlike training. For example, in working life, business professionals might be under extreme pres- sure to reach ambitious sales targets or meet tight deadlines (Rae and Subramaniam 2008; Albrecht et al. 2008). Thus, practicing managers need to learn and understand how illicit behavior can subtly take hold of them (Tenbrunsel and Messick 2004). Normally, professionals are not solicited directly to cheat or to bribe someone. Rather, a slow process corrupts individuals and organizations over time (Ashforth and Anand 2003). For instance, business professionals are sucked into corrupt practices because they get into situa- tions where they feel as though they need to continue along a previously adopted path (Beenen and Pinto 2009).

Research into behavioral ethics has considerably advanced the understanding of decision-making in ethical dilemma situations (Prentice 2014). In this context, Rest’s (1986) four-component model is highly regarded among scholars and is thus frequently referred to in the literature (Craft 2013). This framework emphasizes that a four-step process determines whether a professional will act respon- sibly in a given ethical dilemma situation. The four com- ponents identified by the model are (1) being aware of the ethical issue, (2) making the ethical judgment, (3) develop- ing ethical intention, and (4) engaging in ethical behavior (Scholl et al. 2016).

Rest (1986) states that ethical awareness is the initial stage in the ethical decision-making process. Only when a professional is able to recognize that a given situation involves an ethical dilemma can the issue be addressed, thus showing the fundamental importance of this stage. Once the ethical issue is detected, the professional needs to make judgments about the right course of action to take in the given situation. Thus, in the second stage, the professional

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needs to develop and analyze potential courses of action to be taken in order to address the ethical issue at hand and assess the potential consequences upon all parties involved. After concluding which course of action is most appropriate from an ethical point of view, the professional must develop the intention to follow through on his/her choice. This third stage might be particularly challenging because ethical values regularly conflict with other compelling (business) interests. In the fourth and final stage, the professional must execute the intended ethical action, meaning that he/she has to turn his/her good intentions into responsible behavior in day-to-day business life.

Regarding the sequence of the stages involved in the pro- duction of (un)ethical behavior, Haidt (2001) emphasizes that ethical reasoning is a step that is commonly undertaken post hoc. In a workplace dilemma situation, professionals tend to act intuitively without considering the full implica- tions of their actions, only rationalizing their behavior after- wards. When confronted with ethical dilemma situations, many practicing professionals feel on an intuitive level that they do not have the option to act responsibly, particularly when business interests or personal welfare are at stake (Uhl-Bien and Carsten 2007). Thus, post hoc, they search for justifications for their illegal and/or unethical behavior (Haidt 2007).

The findings of behavioral ethics research question the value of training approaches designed on the assumption that practicing managers will adopt responsible behavior once they have improved their awareness of ethical issues in busi- ness and acquired ethical knowledge (Haidt 2001). It is often taken for granted that professionals put their newfound cog- nitive knowledge into day-to-day business practice follow- ing the training. However, this is seldom the case (Prentice 2014). For instance, Pless et al. (2011) found that while the vast majority of participants in a given training increased their knowledge of and were able to reflect upon responsibil- ity issues, only a minority felt the need to act on that knowl- edge. Furthermore, Hibbert and Cunliffe (2015) highlight that the knowledge of principles alone is inadequate unless professionals understand their role in fostering responsible practice and their ability to act responsibly in legally and ethically challenging situations.

Accordingly, behavioral ethics states that to realize greater influence in day-to-day business practice, ethics and compliance training must go beyond providing a somewhat superficial awareness of the principles of responsible man- agement. Rather, training needs to construct a sense of moral efficacy among practicing managers by providing them with options to act responsibly in ethical dilemma situations (Gentile 2012; May et al. 2014). Thus, behavioral ethics sug- gests that training must strengthen professionals’ ethics and compliance judgment and intentions on an intuitive level. If this is accomplished, a professional will be more likely to

behave responsibly when he/she is confronted with an ethi- cal dilemma in day-to-day business life (Treviño et al. 2006).

Pedagogical Approaches and Role Profiles of Instructors

The acquisition of application-oriented knowledge, skills, and abilities is regarded as the main goal of formal company training programs (Arthur et al. 2003; Blume et al. 2010). Practicing professionals should be able to transfer the newly acquired knowledge and skills flexibly and purposefully to a variety of day-to-day working contexts and situations (Blume et al. 2010; Bell et al. 2017). To facilitate the devel- opment of this ability and competence among practicing pro- fessionals, various pedagogical approaches can be applied, including guided learning, action learning and experiential learning (Michel et al. 2009). Furthermore, instructors have been found to play a critical role in the success of training (Watts et al. 2017).

Guided Learning Instructors play the key role in the guided learning approach, making all key decisions relevant to the delivery of the training. These decisions include defining the learning objectives and desired outcomes of the training, as well as defining the content, learning strategies, educational techniques and media used to achieve the learning objec- tives. This power allows instructors to largely control and monitor all work, interaction and communication processes within the training. Instructors define when and against which criteria to measure whether the participants have achieved the learning objectives. To this end, the instructors evaluate, give feedback, reward or require retraining until the participants meet the required standard. The transfer of knowledge in a guided learning context takes place primar- ily with the help of one-way methods of communication, such as lectures or direct instruction. Because these meth- ods do not involve major active contributions by the train- ing participants, the transmitted information is thus primar- ily internalized in the course of memorization. Hence, this approach is considered a passive form of learning (Wing- field and Black 2005; Michel et al. 2009). Although passive learning is widespread, many scholars argue that training needs to more actively involve participants in order to be effective (Raelin and Coghlan 2006).

Action Learning The concept of action learning aims less at the mere transfer of knowledge but rather at enabling training participants to organize the learning process them- selves and to develop problem-oriented solutions (Sofo et al. 2010). For this reason, action learning-based training programs create space that puts participants in a position to act. Thus, action learning-oriented training programs are based on self-learning, self-organization and self-planning rather than on an experienced authoritative instructor who

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prescribes all aspects of the training (Smith 1993; Barth et al. 2007). This scenario creates an open-process training within which the instructor has to react flexibly and cannot adhere to a rigid training lesson plan (Hackman and Wage- man 2005). The concept of competences plays a central role in action learning. The participants should acquire action- oriented competences consisting of a dynamic mixture of knowledge, understanding, skills and abilities (Delamare Le Deist and Winterton 2005). To acquire these competences, participants are encouraged to explore, discover, test, dis- cuss, plan, discard and rethink as much as possible by them- selves throughout the training (Sofo et al. 2010). The result of the training should consist of a concrete action-oriented outcome that has been created and presented during the training.

Experiential Learning With the experiential learning approach, the instructor does not control the training and there are no predetermined learning objectives. The partici- pants instead learn from relevant experience gained from the training or the day-to-day working environment (Krics- falusy et al. 2018). In accordance with experiential learning theory (Kolb 1984), a number of factors influence learning, including the context, the motivation of the participant, the other peer participants, and the discoveries and experiences of day-to-day working life. Thus, learning can be seen as a byproduct of concrete practical activities. However, for experiential learning to be successful, it is important to understand that experimental exercises alone may not be enough to promote the desired learning. Rather, participants need sufficient time to critically (self-)reflect on their expe- riences (Wingfield and Black 2005). In this context, Kolb (1984) emphasizes that learning is a process and not an out- come. One of the instructor’s primary tasks is therefore to create the necessary time and space for critical (self-)reflec- tion on one’s own experiences and behavior (Rosenbloom and Alejandro Cortes 2008).

Goal of the Paper

Against the background of the extant literature, the aim of the present study is to contribute to the emerging debate on one of the main areas of responsible management learning: ethics and compliance learning in the workplace (Laasch 2018). For this purpose, a multidimensional conceptual framework is proposed for how companies’ ethics and com- pliance training programs should be organized in a manner that enhances their potential to effectively trigger behavior in accordance with the principles of responsible manage- ment. To this end, in the next step, a qualitative analysis of existing ethics and compliance training programs will be conducted. The first goal of the qualitative analysis is to identify the training objectives underlying ethics and

compliance training and assign them to distinct training approaches related to the ethics and compliance decision- making process. The second research goal is to identify the educational techniques that companies use to train their executives and employees and to derive distinct role profiles of instructors who provide training in the field of ethics and compliance. Based on this analysis and upon the theoretical considerations of behavioral ethics research, a conceptual framework will be developed showing how different training approaches and roles of instructors can be integrated into a comprehensive ethics and compliance training program. The suggested consecutive alignment of various types of training tailored to the diverse needs of numerous trainee cohorts at different learning stages should help companies close the knowledge–practice gap observed in the literature.

Methods

Research Approach

The present study focuses on the population of Swiss com- panies that periodically provide ethics and compliance train- ing to their executives and employees. As stated by Hauser and Hogenacker (2014), only 13% of internationally active Swiss companies belong to this category. Predominantly, large enterprises, companies in the service sector, and com- panies that have been confronted with corrupt behavior have implemented ethics and compliance training programs. In contrast, small and medium-sized enterprises (SMEs) and companies belonging to the manufacturing sector tend to pursue such training efforts significantly less than their respective counterparts (Hauser and Hogenacker 2014). Due to the relatively small target group, and to obtain an in-depth and nuanced understanding of the objectives that companies seek to accomplish with their ethics and compliance training programs as well as the educational techniques they use to train their executives and employees in ethics and compli- ance issues, the present study adopted a qualitative approach. Furthermore, this approach was chosen because qualitative research methods are particularly suitable for generating the rich, detailed information necessary to develop conceptual frameworks and investigate sensitive issues (Glynn 2000; Kumar et al. 1993).

Data Collection

Drawing on the considerations of Yin (2009), the underlying research project involved the collection of four different and complementary types of information: interview, focus group, observation, and company document data.

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Interviews

The sampling strategy for the interviews was based on the purposeful identification and selection of key informants with in-depth insights regarding the ethics and compli- ance training programs of their respective organizations or who are otherwise knowledgeable in the field (Kumar et  al. 1993; Glynn 2000; Gioia et  al. 2010). Interview- ees included in-house senior professionals responsible for conducting ethics and compliance training and practicing managers who participated in such training. Furthermore, interviewees included senior managers of external for- profit and nonprofit service providers offering ethics and compliance training, such as specialized law firms, consul- tancies, nongovernmental organizations, and universities.

Consistent with established procedures, interview data were analyzed during the collection process (Glaser and Strauss 1967). Accordingly, additional interviewees were selected based on information identified as essential in previous interviews (Harrison and Corley 2011). This process resulted in an evolving sample until theoretical saturation was reached, meaning that no new aspects emerged from additional interviews (Gioia et  al. 2010; David-Barrett et al. 2017). It is worth noting that theoreti- cal saturation did not occur in all dimensions at the same time. For example, the dimension that was later termed “Raise ethics and compliance awareness and knowledge” reached saturation much earlier than the dimension that is now labeled “Provoke ethics and compliance behavior”. This is because almost all participants reported that an important aim of ethics and compliance training is to sen- sitize executives and employees to the topic. In contrast, significantly fewer participants explicitly mentioned that their training is intended to have a lasting effect on the behavior of their executives and employees. The same is true for the identified educational techniques, as some of them are used by many organizations, while others are only used by individual organizations.

In total, 39 interviews were conducted using semistruc- tured and conversational interview techniques (Ayres 2008; Roulston 2008). Most interviews lasted between 40 and 100 min and, upon permission being granted by the inter- viewee, were recorded. The recordings of those interviews were transcribed verbatim. The interview guide was adapted during data collection to reflect emerging topics (Pratt et al. 2006), and each interview contained open-ended questions about the training objectives underlying the organization’s ethics and compliance training and the educational tech- niques that the organization uses to train executives and employees. Due to the sensitive nature of the topic of ethics and compliance, all participants were assured confidential- ity. Thus, in the quotes displayed in the following sections of the paper, names and other identifying information have

been altered to protect the anonymity of the participants and their organizations.

Additional Data Collection Methods

To enrich the interview content, participants were asked to share and provide additional related company or training documents when possible. These documents included com- panies’ ethics and compliance policies and guidance docu- ments, training records of classroom-based and web-based training, manuals and teaching notes for case studies, and a business simulation. Furthermore, upon permission being granted by the companies, members of the project team participated in various training sessions, enabling to make first-hand observations (McKechnie 2008). Moreover, a focus group workshop was organized to broaden and deepen the discussion concerning initial findings of the underlying research project (Lincoln and Guba 1985; Morgan 2008). The workshop comprised 30 senior ethics and compliance experts from the public and private sector as well as civil society. Workshop attendees were invited based on an exten- sive list encompassing ethics and compliance professionals based in Switzerland. The majority of these individuals par- ticipated in the study only through the focus group meeting. However, some of these participants had also been inter- viewed previously. The workshop group was conducted as a half-day face-to-face expert panel workshop and included roundtable discussions across five breakout groups follow- ing a presentation of initial results. Focus group participants were then asked to share their comments and elaborate on the preliminary findings.

The use of multiple data collection methods provided the opportunity to triangulate the gathered information (Mathison 1988; Gioia and Thomas 1996). The process of triangulation allowed for crosschecking the given informa- tion and examining whether the emerging findings were supported from various perspectives (Harrison and Corley 2011; Gioia and Thomas 1996). Furthermore, triangulation helped to increase the level of knowledge about the current debate regarding ethics and compliance training from differ- ent perspectives and provided important context for better understanding the content, meaning, and implications of the interview data (Mathison 1988).

Data Analysis

In the process of data analysis, an inductive, open-ended strategy was employed (Gioia and Thomas 1996). As men- tioned above, the data structuring process was conducted in parallel with continuing discussions of the emerging themes via additional interviews and conversations with company representatives and content experts. Through the process of iterating between the collected data and the extant literature,

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the scope of the research question was gradually refined and narrowed (Locke 2001). Following the process of gradual abstraction, the qualitative data were first organized into discrete dimensions before being integrated into the pro- posed conceptual framework (Pratt et al. 2006; MacLean and Behnam 2010).

The aim of the first step of the analysis process was to select, categorize and label direct quotes, resulting in informant-centric codes (Pratt 2009; Patvardhan et al. 2015). During the coding phase, words, phrases or episodes were identified in the interview transcripts and in the additional documents that described the training objectives or educa- tional techniques of the companies’ ethics and compliance training programs, or in the documents that the companies used to train executives and employees. During analysis of the data, the training objectives and educational techniques mentioned were compared with those previously identified and coded. New data were assigned to an existing code, or a new code was created. The codes were refined until the state- ments and additional information provided by all partici- pants could be adequately categorized. Using this iterative analytical process, 15 training objectives and ten educational techniques were identified.

The analysis showed that regardless of organization type or industry, the participants shared a rather homogeneous view regarding the specific dimensions of ethics and com- pliance training under scrutiny. Nevertheless, it should be noted that even though consistent dimensions were identi- fied, the organizations represented and discussed by partici- pants do not necessarily share all the training objectives and educational techniques identified. In addition, the analysis revealed that while the widespread training objective—rais- ing awareness—is seen as an important training component by organizations with more sophisticated training programs, achieving increased awareness is considered insufficient if the training does not go beyond that objective.

The aim of the second phase of analysis was to synthesize and cluster the identified training objectives and educational techniques (Crosina and Pratt 2019). By using constant com- parison methods and by relating the data not only across the codes but also to the extant theoretical literature, the 15 training objectives could be assigned to four different training approaches related to Rest’s (1986) ethical decision- making model. Subsequently, these four training approaches could be assigned to three broader training orientations. Based on the same procedure, four different role profiles of instructors could be derived based on the ten educational techniques. Successively, these four role profiles could be assigned to two main focuses of training. The aim of the final phase was to develop the multidimensional conceptual framework by integrating the previously static, standalone dimensions into a dynamic, integrated model. Although the analytical process has been described in a relatively linear

fashion here, in practice, it was much more manifold and iterative, as is typical in qualitative research (Crosina and Pratt 2019).

Findings

Training Approaches and Orientation of Training

The training objectives discussed in the qualitative data indi- cate that companies pursue various goals by training their executives and employees in the field of ethics and compli- ance. As shown in Fig. 1, the identified training objectives can be assigned to four distinct approaches related to the ethics and compliance decision-making process: (a) rais- ing ethics and compliance awareness and knowledge, (b) fostering ethics and compliance judgment, (c) developing ethics and compliance intentions, and (d) provoking ethics and compliance behavior. In a second step, these training approaches can be integrated into three broad higher-level orientations of training characterized as (i) content-oriented, (ii) learning-oriented, and (iii) practice-oriented. These training approaches and orientations will be described and discussed in the following paragraphs.

Raising Ethics and Compliance Awareness and Knowledge

Throughout the analysis of the qualitative data, it became evident that the majority of companies employ ethics and compliance training primarily with the intention of raising awareness and transferring knowledge. Such training fre- quently focuses on three main aspects: first, building aware- ness of the ethical and legal issues executives and employ- ees may possibly be confronted with in day-to-day business operations. As one participant explained, “We are sensitizing people, especially sales. […] They do not have to know eve- rything by heart, only that they keep it in mind” (ID1361). Moreover, another participant emphasized the importance of the sensitization of their executives and employees towards ethics and compliance: “every employee has to do this [train- ing] because awareness has to be present throughout the entire company” (ID1369).

The second aspect is informing executives and employ- ees regarding the prevailing legal and ethical norms as well as the relevant in-house ethics and compliance policies and regulations. Participants described this aspect of ethics and compliance training with comments such as “Employees should understand what is important in terms of legisla- tion, what has to be observed, what is prohibited […], e.g., that corruption is forbidden” (ID9512). Another participant noted that with their trainings, they aim to provide “basic knowledge, e.g., what is trade compliance, why it exists, why

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do we in the [Company] pay attention to it, always referring to our Code of Conduct” (ID6720).

The third aspect is familiarizing executives and employ- ees with the in-house tools and measures available for executing compliance-sensitive business processes. As one participant reported, “It is about imparting the basics to the people who are confronted with this issue in everyday life […] what is the process, what is required” (ID2905). An additional participant summarized the key message of the training as follows: “If you have doubts, go and ask for help, and if you have a compliance-related suspicion in good faith, then speak up, go to the line manager, go to the local compli- ance officer, come to the [global compliance officer] or use the anonymous external hotline, but get in touch!” (ID5236)

This form of training is commonly purely content-ori- ented and monothematic in nature, concentrating predomi- nantly on ethics and compliance issues without incorporat- ing wider business practice issues.

Fostering Ethics and Compliance Judgment

The second approach of specified training objectives focuses on fostering the ethics and compliance judgment of the trainees. For this purpose, models of ethical analysis are introduced to facilitate moral decision-making when ethi- cal concerns arise. The aim is to strengthen the trainee’s ability to intuitively recognize ethical dilemma situations and the various actors involved in them. As one participant illustrated, we “try to give them [executives and employees]

a trained gut feeling regardless of the policy. So that they could also solve a dilemma situation” (ID9512). A second participant mentioned that the aim of their trainings is “Sim- ply, that he [employee] develops a certain feeling for situa- tions when they go in the wrong direction” (ID8849). This is further emphasized by another participant, who said “I want to sensitize product managers to the extent that they can say independently: we have considered these customers and they are red, orange or green” (ID8846).

Furthermore, trainees should learn to identify and select appropriate courses of action that are in line with the prevail- ing legal and ethical norms as well as the internal policies and procedures adopted by the company. For this purpose, they should be able to instantly consider possible conse- quences of various courses of action and exploit additional and alternative ways of acting. As one participant reported, “That is why they [executives and employees] have to find courses of action themselves. […] The transfer [into every- day work life] is so difficult. You have to somehow enable [the executives and employees] to transfer that to their own everyday work life and to think about courses of action” (ID9519).

Ultimately, trainees should be enabled to make right judgments in dilemma situations. One of the participants provided an example scenario demonstrating the type of situation the trainees should be able to successfully manage following the training: “a meeting [with a potential client] took a long time and there are still a few things to discuss. Now the question arises: should we go to a restaurant, and

Fig. 1 Training objectives, training approaches, and orien- tation of training

• Raise awareness • Transfer knowledge • Assess knowledge

• Create a portfolio of responsible courses of action

• Rehearse to act on responsible courses of action

• Reflect critically upon one’s decision- making

• Reflect critically upon the impact of decisions on oneself, the organization, and society

• Intuitively recognize ethical dilemma situations

• Identify the actors involved in ethical dilemma situations

• Identify possible courses of action • Consider consequences of the

courses of action • Select appropriate courses of action

• Act responsibly under pressure • Learn from mistakes • Reflect critically upon one’s behavior

Training objectives Orientation of trainingTraining approach

Content-oriented

Learning-oriented

Practice-oriented

Foster ethics and compliance judgment

Develop ethics and compliance intentions

Raise ethics and compliance awareness and knowledge

Provoke ethics and compliance behavior

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who pays? Ideally, they should be able to solve that them- selves” (ID9512).

Such training is learning-oriented because it gives train- ees the opportunity to apply their learned theoretical knowl- edge about ethics and compliance while remaining in a safe and controlled environment.

Developing Ethics and Compliance Intentions

Once executives and employees have gained the knowledge to identify responsible business conduct, the next step is to develop the trainees’ motivation to act based on that knowl- edge. This is where the developmental training approach comes into play. This training approach aims to help pro- fessionals create a portfolio of responsible behavior pat- terns and to practice these alternative ways of acting. For this purpose, trainees learn, script and rehearse responsible courses of action that they can take if they are confronted with a dilemma situation involving undue behavior. As one participant noted, “Most of the time people know what is right; however, they feel that they do not have options. It is also a behavioral, experiential issue. To address that, people need to rehearse” (ID6725). Furthermore, in the process of such training, trainees should develop the ability to reflect critically upon their own decision-making and the impact of their decisions on themselves, their company, and soci- ety as a whole. To facilitate the trainees’ learning in this regard, one participant stated, “We say that it would also be good if they [line managers] gave their own examples and reflected on what was good and what was less good. So that the employee sees that everyone makes mistakes, but, it is important to reflect on them and learn from them” (ID8849).

Such training is learning-oriented because it should empower the trainees to responsibly address ethical dilemma situations on their own rather than simply passing the issue to the company’s ethics officer while remaining in a safe and controlled environment.

Provoking Ethics and Compliance Behavior

The aim of the fourth approach of the identified training objectives is that trainees learn to act in a responsible way under pressures (similar to those) encountered in real busi- ness life. The goal is for executives and employees to learn specifically what is required to handle arduous situations, rather than asking them to attend a predetermined, standard- ized ethics and compliance training. The individualization and customization of the training content allows learning in accordance with the just-in-time and just-enough principle and ensures that the needs of each executive and employee are met. To this end, executives and employees are encour- aged to openly ask their peers for advice about the course of action to take when confronted with an ethical dilemma

situation. At the same time, the other training participants should be enabled to peer coach on ethics-and-compliance- related topics. The aim is to enact and defend responsible courses of action in the presented dilemma situations and to learn from one’s own mistakes. Furthermore, trainees should learn to reflect critically upon their own behavior. One par- ticipant highlighted the efforts his/her company made in this regard: “We have leader-led compliance sessions, […] where we ask line managers to conduct ethics dialogues with their employees once a year to strengthen reflection but also to build trust” (ID8849).

This training approach is practice-oriented in nature, emphasizing not only ethics-and-compliance-related issues but also other exigent business targets, including tough schedules, tight budget allowances or demanding technol- ogy and quality specifications.

To further delineate the chain of evidence, Table 1 show- cases additional quotations regarding the training objec- tives mentioned by the informants, which have been sub- sequently assigned to the four approaches related to the ethics and compliance decision-making process. These training approaches were then further integrated into three broad higher-level training orientations characterized as content-oriented, learning-oriented, and practice-oriented (see Fig. 1).

Role Profiles of Instructors and Focus of Training

Based on the qualitative data, various educational techniques that companies use to achieve the aforementioned training objectives have been identified. Building on these different educational techniques, four distinct role profiles of instruc- tors who provide training in the field of ethics and compli- ance can be derived (see Fig. 2). These role profiles can be characterized as follows: (a) content-communicator/evalu- ator, (b) subject specialist, (c) guide, and (d) tutor. Drawing on these role profiles in a second step, two principal focuses of the training can be identified, ranging on a continuum from an (i) instructor-centered pole to a (ii) trainee-centered pole. The role profiles and the focus of training will be defined and explained in the following sections.

Content‑Communicator/Evaluator

The educational techniques specified during the quali- tative data collection indicate that most companies pro- vide ethics and compliance training either in the form of classroom-based lectures or web-based training. After the classroom-based training session, participating profession- als usually receive the training records, guidance docu- ments and additional materials for future reference. As one participant described, “The classroom or face-to-face training courses are as follows: a compliance officer stands

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Table 1 Additional representative quotes illustrating training objectives

Raise awareness “[The training] is for a first sensitization, so that one has heard from the subject once. […] However, actually we do not expect much more than sensitization” (ID9519)

“We train sales staff [… with] a general training on the subject of trade compliance in order to sensitize the employees and [to tell them] what they have to pay attention to in their daily work” (ID6720)

“I trained the awareness of almost 300 people here at this branch last year” (ID5232) “The aim of the training is to sensitize employees to the most important risks or to all

risks related to compliance” (ID5238) “You can sensitize your employees with a course, but you cannot give them deep

knowledge with it. I think that is more time-consuming” (ID8849) “The first goal is to create a general awareness of the issues in the Code of Conduct.

[…] They [employees] should have the general awareness that we have this set of rules and if there are any questions, they know where to look” (ID8849)

“We have to make our staff aware of this issue [compliance]” (ID3855) Transfer knowledge “You simply have to tell them [employees]: there is a law, we have to stick to it and we

want to comply with it, and what their task is in the whole process” (ID6724) “It is important that all our employees know that we have a Code of Conduct and what

it says” (ID8849) “Risk-minimization by sensitization, information and instruction of management and

staff” (ID1362) Assess knowledge “And then there is a test at the end: 5 questions that the learner has to answer and pass.

Then, he has completed the training” (ID6720) Intuitively recognize ethical dilemma situations “Participants of [training approach] recognize ethical issues more frequently than

those who have not participated” (ID6725) “The goal is that the participants first understand why this is a risk at all. […] That the

participants themselves actually come to this realization” (ID5238) Identify the actors involved in ethical dilemma situations “[Participants should be able to] identify all the affected parties, customers, managers

at different levels within the organizations, the wider profession, etc.” (ID6725) “[…] specifically geared to our customers, where do we see problems, where do we

need appropriate permits, where do we have to be careful, where are risk areas, etc.?” (ID8848)

Identify possible courses of action “To deal with how to handle such risks, what is expected, how complicated, complex issues or situations can or should be handled” (ID5238)

“We want our employees to understand what they can do, how they should do it and what they should not do” (ID8849)

Consider consequences of the courses of action “And, [what are] the impending penalties” (ID2905) “[…] people have to identify what the impacts on all of them [involved parties] are,

identify and look at the different professional requirements and standards and say which have been violated” (ID6725)

“We take cases such as the [Company A] Case or [Company B]. […] And then, you simply discuss: What happened there? What did they do? What is the consequence? How were they punished? What were the consequences for the company and for those involved?” (ID5236)

Select appropriate courses of action “[Learn] what [behavior] is acceptable and what is unacceptable” (ID9512) “The task of the participants of the training is to find for solutions how to communi-

cate and enact this solution effectively” (ID6725) “It is also important that the employees […] develop a sense of what [behavior] is

right and what is wrong” (ID8849) Create a portfolio of responsible courses of action “I remember a meeting in which it was suggested that it would be good if one would

already start the discussion with: you reject that proposal – when illegal things are proposed. How do you proceed? That people in this case will perhaps better inter- nalized and be more solution-oriented from the outset” (ID9512)

“All trainees are engaged in developing a script and an action plan [ways and solu- tions] for how the protagonist could be successful. Everyone is assigned the task to look for the solution that is most likely to be successful” (ID6725)

“The aim is for the participants themselves to recognize the procedure or the risks and to consider how they could deal with them. […] How could you handle a situation such as that? Therefore, not only: “we are not allowed to do that” but also how we can implement the solution” (ID5238)

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there and conducts a training course […] with case studies based on slides” (ID9512). Furthermore, a second partici- pant noted that “[…] trainings are delivered in a classical way: they [instructors] come with a folder and teach some

theory and general knowledge about trade compliance” (ID6723).

Due to the high costs of classroom-based training, com- panies prefer to use web-based training solutions to raise

Table 1 (continued)

Rehearse to act on responsible courses of action “Professionals need to be trained to take the next step when they witness unethical behavior so that they know who to communicate with, how to communicate it, what is going to be most effective. Start to rehearse and prescript that behavior” (ID6725)

“Thus, let us spend some time together thinking about what you could say and do and start to rehearse and prescript it” (ID6725)

Reflect critically upon one’s decision-making “Think about where the company is affected, where does it stand. […] Just deal inten- sively with these thoughts” (ID6728)

Reflect critically upon the impact of decisions on one- self, the organization, and society

“[We have so called] compliance moments. These are brief reflections at the begin- ning of a meeting about something they [line managers] have seen, e.g., […] where something went wrong” (ID8849)

Act responsibly under pressure “We use real examples from the organization, we try to bring in examples from people who were able – found ways to act ethically even in the face of the existing pres- sures” (ID6725)

“This is exactly what we want to train: To anchor these correct behavioral patterns in the employees” (ID8849)

“We cannot do certain business [due to compliance requirements]. Now, we train our sellers that this does not happen” (ID1369)

Learn from mistakes “[…] the participants also ask questions – and then of course they ask questions about Mr. [Ex-CEO A] or Mr. [Ex-CEO B] too. […] Then, you explain the case and show what consequences [misconduct] can have” (ID9512)

Reflect critically upon one’s behavior No additional quote

Fig. 2 Educational techniques, roles of instructor, and focus of training

Group discussion

Prior to decision case study

Classroom-based lecture

Role-play

Instructor-centered

Trainee-centered

Educational techniques

Moderated plenary discussion

Post-decision case study

Web-based training

Computer-based simulation

Training video

Social media-supported peer-coaching

Focus of training

Subject specialist

Guide

Content-communicator/ evaluator

Tutor

Role of instructor

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awareness and transfer knowledge regarding ethics and com- pliance issues. Compared to classroom-based training, an advantage of web-based training is that it is easily scalable. Once developed, it can be delivered at any time, in any part of the world, to any number of trainees so long as they have access to the Internet. Two participants described the online trainings conducted by their respective companies: “It is simply a training course, which everyone does on their own computer. We do not bring people into a room. It is a com- puter program they have to deal with” (ID2904). In addition, “they [executives and employees] then do the e-learning, this way it is easy to reach the masses” (ID6720).

In addition to raising awareness and transferring cog- nitive knowledge, web-based solutions also offer an easy way to monitor and assess trainees’ knowledge and learning progress. After the completion of the knowledge test, each trainee receives an overview of his/her performance. If the trainee passed the knowledge assessment with the required score, the learning program automatically issues a certifi- cate, documenting that the trainee has successfully partici- pated in ethics and compliance training. As one participant explained, “There is a test at the end of the various training sessions that [the executives and employees] have to take. It is mandatory. Thus, we have proof that they have heard about the topics” (ID9519).

In the context of the described educational techniques, the role of the instructor is that of a content-communicator and evaluator. In this role, the instructor’s task is to raise the trainees’ awareness regarding the prevailing legal and ethi- cal standards. Furthermore, instructors need to ensure that trainees master the knowledge prescribed by the company in order to meet the company’s demands in the field of ethics and compliance. For this purpose, instructors develop and define the instructional strategy, methods and materials, as well as the structured type of examination used to assess trainees’ learning progress. The training methods used in this context are mainly passive teaching methods such as lectures, texts, and videos delivered in either classroom or e-learning formats. As one participant noted, “That simply has to be the content on a few slides” (ID6724). In addition, a second participant stated, “We made a video with our CEO in which he talks about integrity and what it means to him” (ID5238).

The most common techniques used in the tests are mul- tiple-choice assessments. Executives and employees are required to pass these assessments to successfully complete the training. As one participant explained, “At the end, there is a test where you have to achieve eighty percent. These are, for example, ten multiple-choice questions that are used to test what you have learned. You can solve the questions with what you have been taught. […] I would say that it is feasible – not excessively difficult. If you do not manage to reach the eighty percent, then you can just do it again and again. So,

the point is simply that at the end you answer eighty percent, eight out of ten questions correctly” (ID9512).

The focus of such training is instructor-centered; the instructor retains full control of the training. Based on pre- specified objectives, in results-oriented training methodolo- gies, instructors transmit the predefined body of knowledge required for satisfactory completion of the final assessment. At the same time, they monitor and document the attendance and performance of each trainee.

Subject Specialist

Based on the qualitative analysis, it is apparent that some companies use classroom-based training to discuss short sce- narios involving ethics-and-compliance-related situations. Such short, prepackaged case studies are especially used to train executives and employees who work in sensitive posi- tions, such as purchasing managers or sales personnel, who are more likely to be confronted with similar scenarios. The case-study scenarios end prior to decision-making, and the trainees have to choose which decisions would be correct in the given situation. During split-group and plenary discus- sions, trainees are asked to identify and select appropriate courses of action that are in line with the prevailing legal and ethical norms as well as the internal policies and pro- cedures adopted by the company. One participant described the approach taken by his/her company in this regard: “We often take case studies of incidents that have happened in our company or in a similar industry – so that it makes some sense. […] We describe the case and then ask, can we do this? Can we do that? What would you do next?” (ID8849) In a similar vein, another participant described a training based on real-life cases, which are presented in the form of a board game: “Four parties play a board game. In the middle are cards with dilemma situations. One of the participants chooses a card, reads the dilemma situation, and there are different courses of action that are discussed in the group. Everyone has to form his or her own opinion and decide which option to choose” (ID9519).

In the context of the described educational techniques, the instructor acts as a subject specialist. In this role, he/she teaches mainly by example, allowing the trainees to benefit from his/her sound expertise. The instructors usually share their expert knowledge in the form of doctrinal conversa- tions, during split-group and plenary discussions, or in the context of solving a prepackaged case study. Based on his/ her specialist authority, it is the task of the instructor to aid the trainees in critically reflecting on their taken-for-granted attitudes and business practices in relation to the learned subject matter. In this light, one participant noted: “The results from the smaller groups are then shared with the whole group so that the others can hear and discuss it. Then, there are always other realizations. It is important that the

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other groups also comment on what the group thought. And then there is a statement from our side [instructors]: what is important – if something has been forgotten, what would be important to mention, or what other possibilities there are, or what is expected, what one should do” (ID5238).

The focus of such training is mid-way between the two poles of instructor-centered and trainee-centered. It should be noted, however, that the knowledge structure is largely defined by the instructor. The interplay between an authori- tative—instructor-centered—and a reflexive—trainee-cen- tered—training style should facilitate the internalization of the external and internal rules and regulations by the trainees.

Guide

Day-to-day business life is very dynamic and often brings with it immense time constraints and financial pressures. This means that executives and employees must often make decisions with little time to reflect on their actions and the reasoning behind them. Thus, professionals must optimize their responses in order not to lose business while remain- ing within legal and ethical boundaries. To address these challenges, one of the interviewed organizations uses post- decision case studies. In this approach, the case scenario ends when the case study protagonist has already decided what the responsible position is and what he/she wants to do. One participant described the approach employed by his/ her organization in this regard: “In the postdecision-making approach, the presumably ethical and legal response to the given dilemma situation is embedded in the scenario. The task of the participants of the training is to find solutions to communicate and enact this solution effectively” (ID6725).

Thus, the trainees are not asked to choose which deci- sions would be right from a legal and/or ethical perspective. Rather, it is the task of the trainees to develop scripts and action plans necessary for the case-study protagonist to suc- cessfully implement his/her responsible solution to the given dilemma situation. In this way, the training approach allevi- ates the emotional burden of ethics and compliance training because the morality of the trainees is not judged. Instead, their ability to develop, implement, and communicate effec- tive courses of action is fostered. As the participant further elaborated, this form or training encourages the trainees to ask themselves questions such as “How can I raise the value issue effectively in the organization? How can I make an impact? How could middle management bring that valu- able issue to me so that I would be more likely to respond appropriately and be responsive?” (ID6725)

Executives and employees are encouraged to prescript and rehearse appropriate replies and actions in the event that they are confronted with illicit business conduct. Thus, the training helps to build a sense of moral efficacy so that on

an instinctive level, executives and employees realize that they have options to behave responsibly in ethical dilemma situations.

Another examined company uses a training approach in which dynamic, high-pressured real-life situations are mimicked in the form of a computer-based business sim- ulation, also known as a business game or serious game. The simulation is comparable to an interactive case study. However, contrary to a case study, the business simulation closely resembles a coherent decision-making reality, ena- bling trainees to see whether their decisions led to success in the context of the simulation. The simulation is designed to mirror and replicate the structural complexity, interrelated- ness, and lack of transparency that executives and employ- ees experience in a real-life dilemma situation, making the simulation almost as challenging as reality. One participant described this approach as “a kind of flight simulator train- ing where people are tossed into the situation where there is a lot of pressure and then they have to react in the situation as a way to prepare them. […] Even if it is just a game – a simulation, people will act in the simulation like they will behave under real pressure” (ID6725).

However, unlike case studies, the simulation contains an additional playful and game-like element while remaining a didactic tool. The training based on the business simula- tion is characterized by a combination of sessions that use the computer-based simulation and moderated discussions to reflect on the actions taken in the simulation.

Moreover, some companies use role-plays to enact and optimize pragmatic learning. The assignment for the dif- ferent participants in the role-play is to enact and defend divergent perspectives on a given dilemma situation. One participant discussed the use of the role-play method in his/ her company as follows: “I think role-playing loosens up [the training]. It definitely does. It encourages discussion. However, […] it is still far away from everyday work life” (ID9519).

In the context of the described educational techniques, the instructor acts as a guide. He/she helps the trainees engage in their own experience with illegal and/or unethical behav- ior, but in a safe and controlled environment. This approach gives trainees the opportunity to critically reflect on their intuitive reactions and instantaneous decisions in ethics-and- compliance-related situations. Furthermore, as a guide, it is the instructor’s task to help professionals develop a portfolio of responsible behavior patterns and rehearse these alterna- tive ways of acting. The focus of such training is mid-way between the two poles of instructor-centered and trainee- centered. The instructor facilitates the trainee to develop solutions and skills to act responsibly on their own. The role of the instructor is described by a participant who said that people need to be able to “develop skills, strategies, tactics, arguments, and confidence before engaging in [real world

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situations]. […] You cannot just throw people into the deep end of the water and expect that they will be able to swim and not drown. You have to teach them strokes” (ID6725).

To this end, instructors need to create an encouraging and stimulating environment to support the trainees’ inher- ent motivation and their openness to learn from mistakes without fear of recrimination.

Tutor

The qualitative inquiry has shown that individual providers of training solutions as well as one company have started to develop and experiment with training based on peer coach- ing. Executives and employees may find it a daunting task to openly ask for advice from a superior or a peer regarding the course of action to take when confronted with an ethical dilemma situation. Collaborative, web-based tools offer an innovative, attractive possible solution to that issue. In the form of an in-house forum-like web-application, an online communication platform is implemented where executives and employees have the opportunity to interact (anony- mously) with others, voicing their concerns over ethics and compliance challenges they have faced, or may be facing, and ask for advice. With the help of the web-based solu- tion, the individual and his/her peers can share and discuss best practices about how to address and solve the issue. By reflecting on the dilemma situation and suggesting possible courses of action, all professionals active on the platform strengthen their ability to act responsibly. In this light, one participant described how his/her company uses this form of educational technique: “One tool that works very well for us is [social media platform]. […] It is the company’s Facebook. […]. What [the social media platform] allows is not formality, but communication in a much more playful, much friendlier way. In this way, people engage, post, com- ment […]. People are much more directly connected, and it is something that works wonderfully well. […] People start sharing information: what should I do if someone brings me a gift? It is like Facebook. It is not limited to just the management level; it is for the whole company” (ID3858).

In the context of the described educational technique, the role of the instructor is that of a tutor. In this role, it is the task of the instructor to complement the application of knowledge acquired during ethics and compliance training in day-to-day business life while simultaneously achieving business targets. Web-based, forum-like tools or helplines facilitate the tutors’ work. Thanks to these ICT applica- tions, tutors’ support for and interaction with professionals is not limited to formal training sessions but is also extended to day-to-day business life. As a tutor, the instructor sup- ports the self-regulated learning process of the profession- als and can help to successfully tackle issues arising in the field of ethics and compliance. The tutor is familiar with

the prevailing external and internal rules and regulations and can intervene if the peer coach makes mistakes or is in doubt. By establishing the atmosphere and frameworks necessary for self-regulated and peer-assisted learning, the tutor strengthens the ability of the trainees to independently reach responsible solutions to ethics-and-compliance-related issues that arise in day-to-day business life. The focus of such training is trainee-centered. The trainee obtains only the content he/she requires. The instructor provides the pro- fessional on-demand knowledge he/she needs to act respon- sibly. Consequently, the emphasis of the training is on the needs of day-to-day working life rather than on a predefined body of knowledge.

Table 2 lists additional evidence of the educational tech- niques mentioned by the informants, from which four dis- tinct role profiles of instructors have been derived. Based on the instructor-role profile, two principal focuses of the training have been identified, ranging on a continuum from an instructor-centered pole to a trainee-centered pole (see Fig. 2).

Framework

Framework Development

Building on the conceptual considerations of behavioral ethics and the findings of the qualitative data analysis, a multidimensional conceptual framework is proposed. The framework displayed in Fig. 3 integrates various training approaches and the different role profiles of instructors, arranging them in a consecutive manner. The framework posits four dimensions: two dimensions refer to the orien- tation and approaches of ethics and compliance training, while the remaining two dimensions relate to the role of the instructors and the focus of the training.

The three broad higher-level orientations of training are labeled content-oriented, learning-oriented, and practice- oriented. Content-oriented training focuses on providing the means to raise awareness and transfer a predefined body of knowledge regarding ethics and compliance issues. Learning-oriented training takes a developmental stance and emphasizes teaching the skills and solutions required for ethics and compliance judgment and intentions. Practice- oriented ethics and compliance training represent the types of training that concentrate on stimulating real-world practi- cal implementation and enactment of responsible behavior in day-to-day business life and where peer-to-peer learning takes place. Subordinate to each orientation are two train- ing approaches. The distance between each pair of training approaches is shown to be narrower, implying a compara- tively closer proximity within each pair. Moreover, the close relation also suggests a relatively easy crossover from one

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Table 2 Additional representative quotes illustrating educational techniques

Classroom-based lecture “We do not use an e-learning tool for the training because each area has to be trained slightly differently. I have to train the developers differently than the front office staff […]. I truly do it very tailor-made for the region, for the issues in each region and for the people I am training at that moment. […] I know exactly which areas are most affected, thus, I decided to do personal trainings” (ID9518)

“Then, there is face-to-face training as well, we do that a lot” (ID5232) “We go on-site and train people” (ID8841) “I think certain topics need to be personally trained, whether the training is conducted by an internal or

external person” (ID8843) “We do the specific training […] preferably via classroom training” (ID8849) “When someone new joins the organization, I am in charge of giving the face-to-face training” (ID3858)

Web-based training “The topic can be trained very well in e-learning. To a certain extent at least. But, the basic training can be done well with e-learning” (ID2905)

“We are currently introducing an e-tool for trainings on the Code of Conduct” (ID9518) “We have online trainings, simple e-learning formats, […] which are mandatory and sent to people”

(ID9519) “I am a fan of e-learning. But, such e-learning must be different for the different groups, i.e., for the dif-

ferent departments and depending on how they are exposed” (ID6724) “By 2017: Employees with computers completing the compliance e-learning process started in 2015”

(ID3859) “[…] computer-based trainings […] including animated tests, voice narration, video sequences, refer-

ence documentation [… are] available in seven languages” (ID0081) Training video “The training I am referring to is a cartoon in which the characters face different challenges” (ID5238)

“We record short videos for training purposes. Also quite simply with a mobile phone. Two, three min- utes, really fast” (ID5238)

“You can do training courses differently nowadays […]: You no longer get a piece of paper to read, but a film is shown” (ID1361)

Group discussion “The training is classic. One looks at [compliance-related issues] and discusses a lot in a small group” (ID6728)

“There is then a discussion in a smaller group. We have experienced that it is necessary to discuss first in the smaller group because then you can truly reach everyone. Even those who are rather quiet and do not want to communicate actively. This creates a relaxed atmosphere much more quickly, in which you can simply discuss” (ID5238)

“In group discussions, you have to work on cases, present them, give each other feedback, and do role- plays” (ID8849)

Moderated plenary discussion “And then you simply discuss [in a group of 35 people]” (ID5236) “You […] give people as broad a basis as possible of examples and discuss them in classroom training

sessions” (ID8849) Prior to decision case study “These are one-pager cases. However, sometimes they are not so simple. Then, you just ask: ‘What

do you think? How would you solve this case?’ Then, two or three people come forward who say something, and then you refer to that and present the solution by responding to the arguments from the requests to speak. […] Up to forty people can take part in the general compliance training sessions. So this is not an intimate circle that discusses very closely” (ID9512)

Post-decision case study “[In the] post-decision making approach […] everyone is assigned the task to look for the solution that is most probably successful. […] This is a problem-solving exercise […]. Even if they do not agree, people are ask for the sake of the exercise to pretend to be that person that wants to act ethically and find solution how he could be effective” (ID6725)

Role-play “You can prepare [the employees] with the help of methods like case studies, role plays, intensive dis- cussions” (ID8849)

“[Role plays] might have to be recorded. If the participants would try their hand at individual roles and defend their point of view accordingly or consider how to defend it, it would really be interesting to try it out at least once” (ID5238)

Computer-based simulation “The simulation is fun to play. You really get drawn into the game, trying to solve the cases” (ID1367) “The complexity of the simulation is appropriate. Case and dilemma scenarios are realistic. Decisions

are challenging” (ID4673)

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training approach to the other. Conversely, the distances between the three broader training orientations are shown as larger, thus implying that shifting among the three orien- tations requires a more significant change.

The focus of training ranges on a continuum from an instructor-centered pole to a trainee-centered pole. In instructor-centered training, the instructor retains full con- trol. A predefined body of ethics and compliance knowledge is transmitted from the instructor to the trainees, and the instructor merely disseminates the content to the trainees. The trainees’ role is mainly passive, with memorization as the basis for the successful completion of the assessment at the end of the training. The middle position between the two poles is characterized by an active exchange between instructors and trainees. The instructor facilitates the trainee in developing solutions and skills to act responsibly while generally remaining within the knowledge structure defined by the instructor. In trainee-centered ethics and compliance training, the trainee obtains only the content he/she requires. Thus, the role of the instructor shifts towards providing the professional with on-demand knowledge he/she needs to act responsibly in day-to-day business life. Hence, training becomes a continuous process of assisting professionals to responsibly tackle the ethics-and-compliance-related issues that arise at work. Consequently, the emphasis is on the out- come in working life rather than on a predefined body of knowledge.

The vertical relationships in the figure between the four dimensions indicate an interplay between the dimensions in the delivery of ethics and compliance training. On the one hand, the awareness-raising approach is usually con- tent-oriented and instructor-centered, with the role of the instructor being to communicate the predefined content and evaluate the performance of the trainees. On the other hand, the on-the-job peer-coaching approach is typically practice- oriented and trainee-centered with the role of the instructor being that of a tutor.

Discussion of the Developed Framework

The aim of the proposed framework is to contribute to the fostering of ethics and compliance learning in the workplace. Based on a formative, developmental approach (Scriven 1991; Patton 1996), a consecutive alignment of various types of training is endorsed. Drawing on the findings and concepts of behavioral ethics (Rest 1986; Haidt 2007), this judicious mixture of training approaches is expected to help companies close the knowledge–practice gap observed in the literature (Hibbert and Cunliffe 2015; Nonet et al. 2016). In this context, the proposed framework should not be construed to mean that with the exception of the eth- ics and compliance training found on the right-hand side of the framework, all other types of training are flawed and,

Table 2 (continued)

Social media-supported peer coaching “We are setting up training courses [for senior executives], like a kind of reference book, e-book with a platform through which they can network with each other. [They] can log into the platform and com- municate with each other. And, we hope that they will exchange ideas: ‘How did you do it?’ ‘Have you ever been confronted with this issue?’ […] It would be good if there were such mutual learning opportunities for the regular staff too” (ID9519)

“This is also interactive. The employees can also ask questions, in the [virtual] tool it is possible to leave comments and ask questions and we [the compliance trainers] can also react to them, answer them” (ID5238)

Trainee-centeredInstructor-centered

Raising ethics and compliance

awareness

Impar ng ethics and compliance

knowledge

Fostering ethics and compliance

judgment

Developing ethics and

compliance inten ons

Content-communicator/evaluator Subject specialist Guide Tutor

Content-oriented Learning-oriented Prac ce-oriented

through training

experience

through workplace experience

Provoking ethics and compliance behavior

Fig. 3 Multidimensional conceptual framework of a comprehensive ethics and compliance training program

851From Preaching to Behavioral Change: Fostering Ethics and Compliance Learning in the Workplace

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therefore, provide limited value. Instead, the framework sug- gests that all types of training serve specific purposes and, thus, are relevant at specific stages of the training cycle. In fact, the framework proposes a thematically and temporally consecutive order of the training approaches. This means that all the training approaches are necessary; however, they are needed in varied amounts and with different degrees of emphasis and customization, depending on the context and on what has already been taught at an earlier stage. At the same time, the model must not be interpreted as saying that any single one of the training approaches is sufficient on its own. Instead, in accordance with concepts of behavioral eth- ics (Rest 1986), the framework points to a specific thematic and temporal sequence of the training approaches, which companies should use to increase the probability of turning professionals’ ethics and compliance awareness and knowl- edge into responsible behavior.

The qualitative analysis underlying this study indicates that extant ethics and compliance training primarily focus on ensuring that executives and employees are aware of and know what the prevailing external and internal rules and regulations are. Despite the widespread use of content-ori- ented, instructor-centered training in the field of ethics and compliance, various shortcomings of this type of training were mentioned during the interviews. It was stated that such trainings often lead to skepticism and even cynicism among executives and employees because they perceive major inconsistencies between the content of ethics and compli- ance training and real-life business practice (see also Gentile 2013). One participant referred to this type of training as “preach and pretend”. Companies preach to their executives and employees about legally and ethically correct business practice, and executives and employees pretend in the train- ing that they will execute this behavior in real business life, too. However, outside of the training, employees face con- flicting messages and unrealistic pressures from their superi- ors, making it challenging and even almost impossible to act according to how they are taught (see also Leyendecker et al. 2013). Furthermore, it was highlighted during the interviews that training should not approach ethics-and-compliance- related issues as if they were exclusively cognitive con- cerns, implying that the whole problem is that executives and employees do not understand what is right and what is wrong. Indeed, even when professionals know what is right, they often feel that they do not have the option to behave responsibly without, for instance, offending their business partners and losing the deal. Finally, it was mentioned dur- ing the interviews that due to the shortcomings of the extant training programs, the motivation of executives and employ- ees to participate in ethics and compliance training programs is rather low and that companies must find ways to increase the attentiveness of participants. This is seen as particularly important to ensure continuous learning on the topic.

To address the discussed shortcomings and challenges of the existing training programs, the proposed conceptual framework includes three major orientations of training. The first is content-oriented raising of awareness and transfer- ring of knowledge regarding the prevailing ethical and legal standards in the company’s environment, as well as the inter- nal rules and policies of the company that executives and employees must adhere to in day-to-day business practice. Second, the learning-oriented development of solutions and skills is a prerequisite for responsible behavior. Third, prac- tice-oriented experience-based training is necessary for the implementation and enactment of responsible behavior in day-to-day business life. Furthermore, the conceptual frame- work proposes two training focuses ranging on a continuum from an instructor-centered pole to a trainee-centered pole.

Conclusions, Limitations and Implications for Future Research

Despite the increasing inclusion of ethics and compliance issues in corporate training, the business world continues to witness a series of prominent corporate scandals (Hauser and Kronthaler 2013; Schembera and Scherer 2017). This situation suggests the presence of a knowledge–practice gap among professionals, meaning that a discrepancy exists between their knowledge about responsible management principles and their behavior in day-to-day business life (Hibbert and Cunliffe 2015; Nonet et al. 2016). With this in mind, it was the purpose of this paper to address the forma- tive, developmental question of how companies’ ethics and compliance training programs should be organized in a man- ner that enhances their potential for effectiveness. Drawing on the qualitative analysis of extant ethics and compliance training approaches and the conceptual literature on behav- ioral ethics research, a conceptual framework was proposed, aligning various types of training and the role of instructors in a comprehensive ethics and compliance training program. Thus, from a managerial perspective, the aim was to support companies looking to design and implement an extensive ethics and compliance program that can bridge the existing knowledge–practice gap. For this to happen, training must shape business professionals not only intellectually but also behaviorally (Rest 1986; Fiol and Lyles 1985; Hibbert and Cunliffe 2015). Hence, ethics and compliance training programs should be based on a consecutive alignment of various types of training and different roles of instructors. The qualitative analysis suggests that the vast majority of companies have not yet done this.

There are several limitations to this study that should be noted, and they open the way for future research. First, this study is based on qualitative data. The sam- ple of companies is purposely biased in favor of larger

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companies who conduct ethics and compliance training. Furthermore, the list of participants in the interviews and focus group sessions is deliberately composed of well- informed and interested informants. While this approach was used to achieve the research goal, the usual limita- tions of this research design apply. Second, learning is individual (Kolb and Kolb 2013) and cannot be separated from the contexts in which it occurs (Alexander et  al. 2009; Greeno et al. 1996). For instance, some individu- als might be more inclined than others to act unethically in dilemma situations (Hauser et  al. in press). Thus, it can be assumed that individuals respond differently to the various types of ethics and compliance training included in the framework. The same might hold true for individu- als from different countries and cultural backgrounds. Hence, further research should explore how contextual factors and individual differences influence the optimal composition of ethics and compliance training programs. Third, the proposed framework focuses on a standalone training program on ethics and compliance. In the future, however, it will be increasingly necessary to mainstream ethics and compliance issues into other areas of training. Thus, future research should investigate how ethics and compliance can be integrated into other training programs, for instance, leadership development. Fourth, the proposed framework focuses explicitly on formal training programs of companies in one of the three main areas of responsi- ble management learning: ethics and compliance learn- ing. Further research could explore whether the proposed framework is also applicable in the other two main areas of responsible management learning: learning for environ- mental sustainability and learning for socially responsible leadership (Laasch and Moosmayer 2015). Finally, as pre- viously stated, the purpose of this paper was to conduct a formative, developmental evaluation (Scriven 1991; Patton 1996) in order to make suggestions for improving existing ethics and compliance training programs rather than sum- matively assessing the impact of such training programs. However, the proposed framework is amenable to empiri- cal testing and correction. Thus, based upon quantitative data, future research should summatively assess whether the proposed comprehensive training framework helps to narrow the existing knowledge–practice gap among professionals. Furthermore, the results of the formative developmental assessment also provide important input for future summative evaluations of ethics and compliance training programs. Such summative assessments must take into account the four dimensions identified in the concep- tual framework to properly evaluate the effectiveness of the specific type of training under scrutiny (Kraiger et al. 1993). This could help reduce the discrepancies encoun- tered in the extant evaluation literature, which uses a num- ber of variables including differing types of training and

intended measured outcomes (Waples et al. 2009; Maess- chalck and de Schrijver 2016; Watts et al. 2017).

Acknowledgements This paper was partially developed while I was a visiting scholar at the Basel Institute on Governance, associated institute to the University of Basel. I would like to thank the institute for its kind hospitality. Furthermore, I am grateful to my colleagues at the University of Applied Sciences of the Grisons involved in the underlying research projects for their manifold contributions and input, including data collection, translation and language assistance. Moreo- ver, the paper benefited from helpful suggestions and comments on earlier versions by participants of the 5th Responsible Management Education Research Conference, Erica Steckler, the guest editors and three anonymous referees. Funding from the Swiss Commission for Technology and Innovation (CTI) is thankfully acknowledged. The usual disclaimer applies.

Funding This study was co-funded by Swiss Commission for Technol- ogy and Innovation (CTI).

Compliance with Ethical Standards

Conflict of interest Christian Hauser declares that he has no conflict of interest.

Ethical approval This article does not contain any studies with animals performed by any of the authors.

Informed consent Informed consent was obtained from all individual participants included in the study.

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