How to fix a longstanding gap in the company’s compliance program

27 March 2019 - 12:00 am UTC

How to fix a longstanding gap in the company’s compliance program

By  Matt Galvin, VP of Ethics and Compliance at AB InBev and Peter Grossman, Co-Founder of Labyrinth Training.


It seemed like a fairly simple question at the time.  Perhaps it was more of a challenge than a question.  But Matt Galvin, VP of Ethics and Compliance at AB InBev was looking to fix a longstanding gap in the company’s compliance program. 


“Can you make a compliance training video that my staff will actually pay attention to?”


The ask was clear.  And the answer required a skill set that Matt did not have.  But it was a way of thinking that was intuitive to Peter Grossman and his partner Scott Petts (co-founders of  Labyrinth Training). 


Having each spent over a decade in the publishing and entertainment fields, Scott and Peter were well versed in the business of making people stop and look at things.  However, phrases like “Ben Affleck Caught Cheating!” (Peter spent years at Us Weekly,) and “Game of Thrones” (Scott won an Emmy for his interactive design work on the HBO hit’s official site,) have built-in audiences and WOW factor.  The same cannot necessarily be said for the finer details of the FCPA.


The subject of the first training video was Anti-Corruption.  Obviously, getting the policy points across to staff was important.  However, as storytellers, Scott and Peter were equally, if not MORE interested in the real life applications.  “What’s the craziest thing that’s actually happened to you in your professional life?” suddenly became as important as “What does our policy say?”  There would be a lot of back and forth throughout the process, but the end result hinged on a few key questions – those that related to what we now refer to as the Three E’s:  Entertainment, Engagement and Education.


“Can it be a cartoon?”


Admittedly, and much to their credit, the AB InBev compliance team was very quick to approve this idea.  There’s a reason for that, though, and it’s not just because Matt likes cartoons.  EVERYONE likes cartoons.  They trigger the very powerful nostalgia switch in all of us, bringing us back to our childhood where the things we watched were FUN to watch!  Aside from the immediate impact of seeing a stick figure moving around where you’d previously been force fed a PowerPoint slide, animated characters and the scenes they inhabit help to create and immersive environment that the viewer is excited to be a part of.  They also serve to eliminate ambiguity.  We knew we were telling stories with these trainings, and the animated characters allowed for quick and direct communications.  A giant drop of sweat pouring down a frightened face, a sly smile above a stubble-covered chin – what better way to illustrate that the main character is scared they may have just bribed a local government official or depict a local ‘religious’ figure trying to sell you ‘Sacred Cows’ in exchange for cooperation with building the site (for those asking, the answer is ‘Yes, that IS an actual scenario in the training!’)  Presenting the lessons in animated story form sent a clear message from the moment the user clicked play – This is unlike any training you’ve ever taken.

“Can we let the user choose the story path?”


When Scott and Peter presented this idea to Matt, the initial response was, “I don’t know…can you?”  Fortunately, Scott’s background in video and interactive experiences made the answer a resounding ‘Yes.’  The idea of incorporating choice was an integral part of moving the trainings from “Compliance” to “Ethics” and compliance.  For AB InBev,  “Compliance is about teaching people what the rules are…Ethics is about empowering people to make principled decisions in a complex world.”   The trainings needed to invite choice and the user needed to make the decisions and see how they would impact outcomes for the business and for themselves.  That led to another innovation – structuring the trainings as a Choose Your Own Adventure. The Choose Your Own Adventure series was a staple of all of our childhoods and the same concept was applied to the initial Anti-Corruption module.  It would be one thing to watch the main character meet with the Governor of the local province and choose whether or not to meet with the Governor’s ‘people’ about securing land for a site build.  It is another experience altogether to DECIDE whether or not the main character is going to take that meeting!  Engagement is a word that is thrown around a lot in the digital entertainment world.  How can you get the end user to click this/watch that/stay on that screen?  The lessons being taught during compliance trainings have such far reaching implications, engaging employees when they’re being taught should be of paramount concern.  Companies stand to lose millions in fines and lost productivity in ways that COULD be avoided if employees simply followed the rules.  With so much at stake, it is incumbent upon the company to engage their employees whenever important information is being disseminated.  Are you more likely to pay attention to your favorite show, or the lecturer at the front of the class?  We all remember what the teacher from the Peanuts cartoons sounded like to Charlie, Lucy and the gang, right?  If that’s what your employees are hearing from you, you haven’t engaged them and they’re about as likely to remember your policies as Charlie Brown is to finally kick the football from Lucy’s hold.


“What if we don’t necessarily allow for right answers?”


This was the toughest battle.  Matt, being a lawyer by trade, couldn’t comprehend of a situation with no ‘correct’ outcome.  “Lawyers tend to think the highest form of expression in life is a well-crafted exam.  It was this realization that brought Matt to realize that perhaps lawyers aren’t the most popular kids at school.  But as the module came to life, it became clear that this was a lesson – not a test.  The idea that there are simply good actors and bad actors doesn’t have basis in the real world.  Everyone believes they are the hero of their own story.  The question in scenarios related to corruption isn’t ‘would you do the right thing?’ It is far more nuanced.  It’s more, ‘Here is a scenario that you couldn’t possibly have imagined – What are the different ways one COULD do the wrong thing?’  The goal of training is to educate; to effect behavior.  As such, to teach ‘do this, don’t do that,’ paints a misguided image of the world as binary.  By providing multiple scenarios for the user to choose from – most with comedically tragic consequences – the user is sent the message:  “You’d do what you think is right, but it could STILL be wrong – here’s how.” 


“Did you buy the cows?”


It’s a strange question to be asked after you’ve taken a compliance training, isn’t it?  But that’s what the staff at AB-InBev asks each other after taking the training.  And that’s the object of the exercise.  Because asking that question means people are talking about it!  A compliance training is the subject of conversation!  And this will form the basis for how AB does everything from anti-sexual harassment to digital ethics training.  As Matt says, “I hope it doesn’t just make good training, but that it elevates the function so that people understand how compliance can be a key strategic partner in getting things done.  And perhaps we’ll get invited to our bar more often for a beer.” So the answer it seems is, “Yes.”    You CAN make a compliance training that your employees will actually pay attention to.  Like any other good business practice, you just need to focus first and foremost on your employees – their attention – to create an environment that fosters people’s inherent desire to learn about the world around them.  


Matt Galvin is the Global Vice President for Ethics an Compliance for AB-InBev. Matt’s team covers anti-corruption, competition, litigation, sanctions, anti-money laundering, data privacy, human rights and internal investigations.  He is recognized as a leader in the application of data analytics to solve compliance problems and streamline compliance systems and processes. Matt is a NY and Hong Kong qualified lawyer who spent ten years in private practice before joining ABI in 2015.  






Peter Grossman is a Co-Founder of Labyrinth Training, specializing in animated, interactive corporate trainings.  Peter’s diverse professional background includes over a decade as a celebrity journalist which followed his time as a music teacher. He lives in Brooklyn, NY with his wife and three children