Picture the gifts rule again: no gift over £50. For it to count, three things have to be true. It is written somewhere a person can find it. The person was taught it before they needed it. And when they followed it, something recorded that they did. Written, taught, proved.
Told the rule1,000 staff, made up
Finished the training600 staff, made up
Picture a company checking itself on that rule. The policy exists: written, yes. The training was sent to 1,000 staff, and 600 finished it. The second number is smaller than the first, and a watcher reads the smaller one. The numbers are made up.
2 of 10
of every ten gifts offered, recorded
The same company's register has 40 gifts in it. The sales team was offered about 200. What does a watcher see?
A rule that 160 gifts went past with nothing written down.
Right. Forty of two hundred is one in five. The other four in five are unknown: under £50 or over, taken or refused, nobody can say. A register that misses four gifts in five cannot show the watcher the rule was kept.
A rule that is working. Forty entries is a lot.
Not yet. Forty is a lot against zero. Against two hundred it is one in five, and a watcher counts against what was offered, not against nothing.
Nothing. The gifts were all under £50.
Not yet. The register is for every gift offered, so the limit can be checked. A gift nobody wrote down cannot be shown to be under anything.
Well designed?→Applied in earnest?→Works in practice?
The American prosecutors who judge companies ask three questions, and they have published them. Is the programme well designed? Is it applied in earnest, with real people and real money behind it? And does it work in practice? A company can pass the first with a document. The second and third need the training and the records.
Each card is something a company can show. Which of the three questions does it answer?
One card at a time. Tap the pile it belongs to.
Card 1 of 6
A 20-page policy with every rule in it
A compliance team of six, with a budget
Last year's register with 190 of 200 gifts in it
A training course every new starter must pass
A flow chart of who approves what
Three breaches found by the company's own checks, and fixed
A 20-page policy with every rule in it → Designed
Not yet. Designed. A policy shows the rules were thought about and written. It cannot show a single person read it.
A compliance team of six, with a budget → Applied
Not yet. Applied. People and money are what in earnest means; a programme with no staff is a document.
Last year's register with 190 of 200 gifts in it → Works
Not yet. Works. A record that matches what really happened is the only thing that answers the third question.
A training course every new starter must pass → Applied
Not yet. Applied. Training is the programme reaching people; it shows effort, not yet results.
A flow chart of who approves what → Designed
Not yet. Designed. A chart is a plan of the checks. Whether anybody follows the arrows is a different question.
Three breaches found by the company's own checks, and fixed → Works
Not yet. Works. A programme that catches its own breaches is one that is running; a company with no breaches to show may simply not be looking.
2Designed
++
2Applied
++
2Works
Right. Two each. Paper answers the first question, people and money the second, and only a record of what really happened answers the third.
Picture 1,000 staff. Move what the training is like and see how many could say the gifts limit a month later. Made up to show the shape.
Could say the limit150 of 1,000, made up
Staff1,000 of 1,000, made up
What the training is like: An email with the policy attached
An email: 150 of 1,000 a month later. Most people did not open the attachment.
Could say the limit400 of 1,000, made up
Staff1,000 of 1,000, made up
What the training is like: A 20-minute online course
A short course: 400. It was read once, and a month is a long time.
Could say the limit650 of 1,000, made up
Staff1,000 of 1,000, made up
What the training is like: A course with a test you must pass
A course and a test: 650. The test made people read it twice.
Could say the limit900 of 1,000, made up
Staff1,000 of 1,000, made up
What the training is like: A course, a test, and a reminder when a gift is offered
A reminder at the moment of the gift: 900. The rule arrived when it was needed.
What is the training for?
Passing the test.
Not yet. Passing lifted the number to 650. The reminder at the gift lifted it to 900. The point is the moment the rule is needed, not the score on the day.
A record that everyone was sent it.
Not yet. The email frame is exactly that record, and 850 of 1,000 could not say the limit. Proof that it was sent is not proof that it landed.
A hand that knows the rule at the moment it is tested. The reminder at the gift did more than the test.
Right. The test lifted it to 650; the reminder at the moment of the gift lifted it to 900. What matters is whether the rule is in the hand when the gift is on the table.
Move the control.
It was done
↓→
It was written down
↓→
What the watcher sees
The record is the part people skip, and the part the watcher reads. The watcher was not there. It cannot see the hand washing or the ID being checked, only what was written down. And the company reads its own records too, and fixes what they show. A rule nobody looks back at is one nobody can say is working.
The watcher asks: show me the gifts rule was followed last March. Tap the thing that answers.
Tap the part of the picture that answers it.
The policy
++
The training log
++
The gifts register
The gifts register
Right. The register shows what happened in March: what was offered, what was taken, what was refused. It is the only one of the three that is about last March at all.
The policy
Not yet. The policy shows the rule exists. It existed in March and it exists now, and it says nothing about what any hand did.
The training log
Not yet. The log shows people were taught the rule, which is the second question. Whether they followed it in March is the third, and the log cannot say.
The policyon the website
++
The trainingcertificates
++
The log?
A school says it has a bullying policy. An inspector asks to see that it works. Which of these answers?
The policy on the website.
Not yet. That shows the rule is written, which is the first question. The inspector asked the third.
The log of reports, what was done about each, and how long it took.
Right. A record of real cases and what happened to them is the only thing that shows the rule reaching a hand. The other two show it was written and taught.
The staff training certificates.
Not yet. They show the rule was taught, which is the second question. A trained teacher who never logged a report is a rule that stopped at the training room.
Lesson complete
A rule counts when it is written, the hand was taught it, and a record shows it was followed.