Earlier this week, an article by Arielle Bikard in Compliance Week talked about the policy implications regarding the class-action suit against Wal-Mart. That case alleges that Wal-Mart’s nondiscrimination policy was too vague, allowing too much latitude among store-level managers and not properly shaping behavior—while the home office was aware of the situation and, by not changing the relevant policy, failed to prevent the problematic behavior. This situation illustrates the role that policy communications play within a large organization.
Companies are challenged to find the right balance between policies that provide enough guidance to be useful and those that remove the employee’s opportunity to use personal judgment. As Bikard said, “We in the compliance community talk all the time about the benefits of “principles-based governance.”
Adequate management of corporate policy ensures that employees at all levels of the organization are aware of the company’s guidelines. A best-practices approach says to write and manage policies in a templated, standard format and can present them to the user in a compelling fashion that encourages retention. I would refer to this as “policy-based governance.”
What the article did not go into regarding the Wal-Mart case, and what I’ve not seen discussed elsewhere, is whether or not there was any quality training or awareness program within Wal-Mart to address its discrimination policies. It begs the question, not only were the policies too vague and were they not governed well, but was there adequate and effective training? Relevant training at appropriate intervals can further improve the understanding and retention of policy and can increase the likelihood that employees’ judgment calls will result in the right decisions for the company.