The purpose of internal corporate training can range from meeting regulatory requirements to building workforce capabilities to meet operational needs.
An excellent case study is PricewaterhouseCoopers (PWC), an international provider of audit, consulting, and tax services. One of the Big Four accounting firms, along with Deloitte, EY, and KPMG, PWC is the second-largest professional services network in the world.
During a published regulatory investigation conducted on PWC, fines of over a million dollars (CAD) were assessed after it was found that junior staff, managers, directors, and partners of PwC shared answers to tests on auditing, accounting, and professional independence internal training courses.
According to the regulator, PWC "failed to establish policies and procedures... to provide the Firm with reasonable assurance" relating to internal training.
Our conversation with private company leaders revealed that regulators don’t stipulate specific oversight requirements, just the simple outcome expectation that their workforce is “trained”.
Generally, online "training" records are not proof of training, but rather proof of "training-accessed" and not by whom. As a result, the company leadership does not have evidence of individual workers' participation in the training, nor does it have a process in place for ensuring they attended.
When facing potential regulatory or legal action, affected organizations turn to insurance protection - but insurance policies do not cover bad faith or gross negligence.
The argument that company leaders have demonstrated gross negligence is based on the definition of gross negligence as an "indifference to a legal duty of care”, ref Hart v. Kline (1941).
Through our work with best-in-class organizations, Integrity Advocate is able to eliminate all concerns relating to fines, legal judgments, and regulatory interpretations by verifying the identity and appropriate participation of internal personnel in internal training.
In the words of a client senior leader, "how we deliver information to our personnel is indicative of the importance of that information to them".