Ethics training is invariably arranged in a ‘push manner’, with a central learning and development function pushing out an ethics course or two across the insurer. It’s become a bit like insurance itself: something more often sold than bought. And just as many want to see insurance turn itself into more of a ‘bought’ purchase, ethics training needs to go the same way too. People should stop being passive recipients of generic ethics training. Instead, they should understand what ethical issues are important to their work and then ‘pull’ ethics training from L&D to help them manage those issues.
There are five categories of people who I would expect to be ‘pulling’ ethics training out of an insurer’s L&D function.
- individuals and teams whose role creates an above average exposure to a particular ethical risk.
- compliance people who want certain conduct exposures to be dealt with by more than just policies and controls. This is especially the case where containing those exposures relies on more than usual levels of judgement.
- a risk officer who wants greater assurance that people in functions associated with high ethical risk (such as claims and counter fraud) are equipped with the right knowledge and skills to make ethically valid decisions.
- a senior executive who wants to shift the energy for delivering the firm’s ethical vision over onto middle managers.
- non-executive directors who want reassurance that the firm’s capacity to deal with complex or emerging ethical issues is sufficiently developed. Data ethics is an obvious and current example of this.
What emerges out of this is a more empowered workforce taking greater ownership of the ethical issues they have to deal with.
The Key Link
The key link in making all this happen is of course a knowledge of the ethical risks, at the level of the firm, the function and the individual / team. Unless that exists, the firm and the people working for it are, to be honest, just going to be trundling along as usual, reacting to ethical issues as they arise, rather than managing them.
Is generic ethics training a sign of a reactive rather than managed approach to ethics? Yes, it is. And this will be something that the regulator will take note of, ready to question a chief risk officer or head of compliance about why they think a reactive approach to ethics is a good idea. Rather them than me.