Guillem Casòliva, PhD, CCEP-I, Senior Ethics & Compliance Advisor, EMEA & APAC at LRN, sat down with Professor Christian Hauser, a leading researcher in behavioural ethics, to discuss how compliance training is evolving. Their conversation explores why raising awareness alone is no longer enough, how behavioural science can help drive ethical decision-making, and the opportunities and challenges AI presents for the future of ethics and compliance programmes.
Q1. Based on your research and industry observations, what has been the most significant shift in ethics and compliance training programmes over the past five years?
Professor Christian Hauser: When I speak to companies about their training programmes, I’m not convinced that they have made as much progress as one might expect. Many programmes still focus on raising awareness. They explain what corruption or conflicts of interest are, and why they are wrong. But they often stop there.
There is still a widespread belief that if you tell people what is right and wrong, they will naturally follow the rules. However, behavioural science and behavioural ethics have shown that this simply isn’t enough. Take the simple example of jaywalking. Everyone knows that crossing a red light is a citable offense, yet many people still do it. They rationalise their behaviour by saying things like: 'There are no cars,' 'I’m in a hurry,' or 'No one got hurt.'
The same thing happens within organisations. Employees often know the rules, but don’t always follow them. Therefore, training needs to focus not only on raising awareness, but also on actually changing behaviour.
Q2. Your research discusses the gap between knowledge and practice. How can compliance training help close that gap?
Professor Christian Hauser: Raising awareness is an essential first step. Some people are genuinely unaware that certain behaviours constitute misconduct. For example, gift-giving and facilitation payments are so normalised in some cultures that people may not realise they could be illegal.
However, awareness alone is not enough. After awareness comes judgement and intention—the willingness to behave ethically. Then, the next step is to put this good intention into practice in real situations. Approaches such as Giving Voice to Values are valuable because they enable individuals to script and rehearse difficult conversations in a safe environment.
Much of our behaviour is based on habit, or what we might call 'muscle memory'. If someone encounters an unethical request for the first time and has never practised how to respond properly, they are much more likely to make a poor decision. Therefore, training should help employees practise how to respond when they find themselves in ethically challenging situations.
Q3. Does that mean organisations should use different training formats for different objectives?
Professor Christian Hauser: Absolutely. Online learning is an efficient way to raise initial awareness, as it allows organisations to communicate core concepts to large numbers of people. However, different learning methods are required for later stages, such as discussion, role play, simulations and opportunities to practise difficult conversations.
Today, technology also offers new possibilities. These activities no longer have to be face-to-face. Virtual environments and new digital tools make behavioural practice much more scalable than it was a few years ago.
Q4. New technologies such as AI and immersive simulations seem to create opportunities for more realistic learning. What is your view?
Professor Christian Hauser: This is actually an area that I am currently researching. We recently had a paper accepted which explores the use of virtual reality and metaverse technologies. AI is of particular interest to us because it can act as a role-play partner during training sessions. Traditionally, someone had to play the 'wrongdoer' during role plays. The problem with this is that the person repeatedly practises unethical behaviour.
AI enables us to delegate this responsibility while providing learners with realistic practice. However, this raises new techno-ethical questions. For example, could we unintentionally be teaching AI to become a supervillain if it learns unethical reasoning through these simulations? These are exactly the kinds of questions that AI ethics research now needs to address.
Q5. Many organisations are moving beyond completion rates when measuring training effectiveness. How do you think effectiveness should be measured?
Professor Christian Hauser: Completion rates are based on the assumption that employees will behave accordingly once they are informed. However, experience shows that this is not necessarily the case. We are currently developing success-oriented compliance KPIs. This is challenging because compliance competence needs to extend across the entire organisation, not just within the compliance function.
Ultimately, we would like to measure behavioural change. To this end, we have developed a simulation-based serious game in which participants are confronted with realistic business pressures, such as meeting deadlines and budget targets while maintaining quality standards and dealing with ethical dilemmas. These simulations provide valuable behavioural data.
However, organisations have expressed concerns about using these assessments for promotion or hiring decisions due to issues regarding employee privacy and workers’ rights. Therefore, although it is technically possible to measure effectiveness based on behavioural outcomes, organisations need to implement this approach very carefully.
Q6. Some organisations measure knowledge retention, reporting activity or ethical culture after training. What are your thoughts on these approaches?
Professor Christian Hauser: All of these can be valuable indicators. However, traditional metrics often evaluate everyone in the same way, assuming that a training programme has the same impact on all employees.
In one of our current research projects, we asked participants whether they would approve of projects that raise ethical questions. We discovered something unexpected. Questions commonly used by companies to support ethical decision-making, such as 'Would I be proud if my family and friends learned about this project?' or 'Would the public approve of this project if they read about it in the newspaper?', are helpful when it comes to employees who have already a strong sense of ethics. However, they also make individuals with a weaker sense of ethics more likely to make unethical decisions by rationalising this behaviour. We call this the 'boomerang effect.'
For organisations, this means that tracking a single, aggregated metric can be misleading, as a programme may actually trigger unintended behaviour in certain subgroups. Therefore, evaluation and training cannot be one-size-fits-all. Organisations need to understand their employees’ personalities and adapt their approach accordingly.
Q7. Should compliance training become more personalised?
Professor Christian Hauser: Yes, training should differ according to an employee's responsibilities, level of risk exposure, and behavioural predispositions. For example, the training needs of someone working in procurement or sales are significantly different to those of someone who never interacts with customers or suppliers.
Technology is making this type of personalisation increasingly possible. However, organisations must also respect employee privacy and workers' rights. We should never compromise ethics in the name of improving ethics programmes.
Q8. There is increasing pressure to make compliance training more engaging. Is engagement the same as effectiveness?
Professor Christian Hauser: Not necessarily. Nowadays, many companies produce training videos that are almost as sophisticated as those on Netflix. Making training less boring is certainly a positive step.
However, engagement alone doesn’t guarantee behavioural change. If a video only increases awareness, it has only addressed the first step. Several other factors, such as judgement and intention, need to be trained before behaviour actually changes. We shouldn’t confuse entertainment with effectiveness.
Q9. Behavioural science has transformed many fields. Why hasn't it been more widely adopted in compliance?
Professor Christian Hauser: Behavioural science has advanced tremendously over the past 15 to 20 years. Unfortunately, many compliance functions still primarily adopt a legalistic approach. The law naturally focuses on demonstrating compliance when something goes wrong.
Behavioural science, on the other hand, focuses on preventing problems by changing behaviour before misconduct occurs. I believe that compliance professionals increasingly need training in behavioural science so that they can move beyond primarily legalistic approaches.
Q10. How can organisations begin applying behavioural science without being highly mature?
Professor Christian Hauser: Organisations also undergo a process of maturation. Initially, a legal compliance approach may be appropriate to establish minimum standards, for example following a major scandal.
However, as organisations mature, they should progressively integrate behavioural science into their ethics and compliance programmes. The objective then shifts from merely proving compliance to helping employees to behave more responsibly.
Ultimately, compliance should help organisations to perform better in terms of not only legality, but also finance, quality, innovation, ethics, and stakeholder trust.
Q11. What role does nudging play in ethics and compliance?
Professor Christian Hauser: When used appropriately, nudging can be a powerful tool. For example, changing defaults, providing decision-making reminders or offering contextual guidance can significantly improve behaviour.
However, people quickly recognise when they are being manipulated. Therefore, nudges should genuinely help employees rather than simply serve organisational interests. One example would be to provide travel-related compliance guidance just before an employee travels to a higher-risk country. This information is provided when it is needed most.
Q12. How do you see AI transforming compliance over the next three to five years?
Professor Christian Hauser: I believe that AI offers enormous potential. For example, it can enhance investigations, deliver more engaging training and support numerous compliance activities.
However, at the same time, organisations must also carefully manage the risks involved. AI systems must be designed with ethics in mind from the outset. We also need to recognise that AI can empower malicious individuals. For example, fraudsters could use AI to generate convincing fake invoices and sophisticated scams. AI is therefore both an opportunity and a threat. As with any powerful technology, its impact depends entirely on how it is used.
