eBay Inc.'s mission of pioneering new communities around the world built on commerce, sustained by trust and inspired by opportunity, has made it a global Internet powerhouse. Founded in 1995 by Pierre Omidyar, eBay was created to be a "force of good" that prides itself on global citizenship, and aims that its core businesses positively impact the world.
Headquartered in San Jose, California, the eBay family consists of three major operating segments led by eBay, which facilitates the sale of new and used goods around the world (more than $59 billion in goods were sold in 2007, alone), PayPal which serves as a paperless financial transaction company, and Skype which enables energy- and cost-efficient global communications.
Challenge: Manage an Ethics and Compliance Program for a Global Workforce with Local Relevance
With thousands of employees stationed throughout the world, eBay realized its biggest challenge was to implement global policies that are sensitive to local cultures, and the varying job-specific training requirements of its workforce. eBay partnered with LRN to create and effectively operate an ethics and compliance program that accommodates regional, cultural, and job differences while maintaining consistency in overall corporate compliance. Over the years, eBay has embraced the ongoing challenge of customizing ethics and compliance training for its global employees, leveraging LRN’s solutions to maintain cultural and organizational relevance.
eBay's biggest challenge was to maintain a level of relevance in its education that is both timely and meaningful for the different groups and settings in which it is offered. From the beginning, eBay realized that in order to encourage campaign acceptance, management had to champion the program’s values of ethics and compliance through consistent "tone from the top" messaging. Because of eBay’s global presence, they needed targeted and tailored approaches to train many different segments of employees in various risk areas.
Solution: Tailored Global Learning at All Levels to Garner Focused, Meaningful Results
Together with LRN, eBay consulted stakeholders to develop goals and key milestones for the ethics and compliance program. The company training focus stems from its formal risk assessments and consultations with its leadership, legal department, human resources, and business units. Based on the identified priorities, the training is designed with risk mitigation in mind. All training initiatives are based on collaborative discussions with company departments, ensuring that messages resonate clearly, with minimal impact on employees’ time. eBay's global span necessitates that its training modules be available to every employee via LRN’s Legal Compliance Ethics Center (LCEC) learning management system available 24/7 and offered in a myriad of languages including: Chinese, Dutch, English, French, German, Italian, Korean, and Spanish.
LRN's secure, reliable platform allows easy access to subjects including data protection and privacy, anticorruption, anti-bribery, workplace dynamics, as well as environment, health, and safety requirements. Campaign Manager, a key feature of LCEC, helps eBay manage a complex curriculum plan, automating course assignments for new hires and employees at all levels of the enterprise.
eBay also incorporates LRN's courseware within its Compliance Playbook, an annual document that helps eBay implement and administer company-wide ethics and compliance training across its different regional and cultural audiences. The Compliance Playbook helps eBay’s team stay on top of ethics and compliance training by letting them focus more on content development than on administering and documenting the program.
eBay realizes that managerial participation and completion of course education is a key indicator of a healthy compliance framework. As a result, the management team is actively involved in the ethics and compliance program, leveraging internal champions to encourage close interaction with training that speaks directly to company priorities. eBay's CEO, John Donahoe, gives the video introduction to the company’s Code of Conduct course which reinforces the importance of ethics and compliance training to the company as a whole. Other members of the management team appear in ethics and compliance videos to relay messages related to their specific areas of focus, making content as relevant and personal as possible. A great example of a department-specific cascade approach comes from Chief Financial Officer Bob Swan, who is featured in a video explaining the importance of financial integrity. eBay finds that setting this tone from the top ranks of the company sets a strong example that aids understanding and adoption of policies and procedures. This active engagement and support from members of the executive team sends a purposeful message and tone to ensure that eBay employees are properly engaged and that training is part of their daily work environment.
Result: A Sustained Learning Environment that Promotes Behavior Change through a Values-based Culture
The ethics and compliance program is metrics-focused to mirror eBay’s culture. eBay prides itself on its 95 percent completion rate for its ethics and compliance course training that reaches nearly 15,000 employees worldwide. All of eBay's vice presidents support managers to ensure compliance training is seen as a company-wide priority. Additionally, LRN sets tracking and measurement for every step of the compliance program, providing eBay employees and managers with multiple reminders and metrics summaries to facilitate target objective completion.
"Given the varied and vast nature of our corporate audiences, it's necessary that we collaborate with a company that allows us to communicate with our far flung workforce," says Amyn Thawer, eBay's corporate compliance counsel. "LRN's solution helps us message our values-based corporate culture through meaningful training at every level, and in all corners of the globe."
Doug LaBahn is vice president of LRN Solutions. For more information, visit www.lrn.com.