
Your new manager is a compliance risk (but they don’t have to be)
We’ve all seen it happen. Your company’s best salesperson gets promoted to sales manager. Or maybe you hire a seasoned director from a competitor, assuming their years of experience means they’re ready to hit the ground running. They’re rockstars at their jobs, so they’ll be great at leading a team, right? 🤔
Maybe. But probably not without some help.
The skills that make someone a fantastic individual contributor don’t magically translate into being a great people manager. And that manager title from another company is no guarantee they received the right training there, or that they intuitively know your org's specific policies and procedures. This is where we, as compliance professionals, often see things go sideways. A new manager, trying their best but lacking the right tools, can quickly become one of the biggest risks to your organization.
They might deny an employee's request for a different desk chair, not realizing that the request was meant as a reasonable accommodation. They might try to "handle" a complaint about inappropriate jokes themselves, not realizing they’re supposed to loop in HR. Or, they might inadvertently retaliate against a team member who raised a concern, simply by changing their project assignments.
It’s not malicious. It’s a lack of training. And it’s on us to fix it. ⚒️
The problem with "day one" training
So, we train them, right? We pull them into a full-day orientation on their first day as a manager and throw everything at them: wage and hour laws, FMLA, ADA, anti-harassment, conflicts of interest, and the entire code of conduct. They sign an acknowledgement, and we check the box. Donzo!

Bada bing, bada boom. | Source: @adsteam Giphy.com
If only it were that easy… Behavioral science tells us that this is one of the least effective ways to teach anyone anything. It’s called cognitive overload. 🤯 When you bombard someone with too much new information at once, they retain not some, but almost none of it. Especially when they’re already stressed about their new role.
The key isn’t to train them on everything at once. It’s to give them the right information at the right time, in small, digestible pieces.
A better way: Spaced learning for new managers
Instead of a one-time info dump, let’s think about a new manager’s first few months as a journey. 🗺️ We can guide them along the way, giving them just what they need, just in time. This approach, known as spaced learning or microlearning, is proven to increase retention and actually change behavior.
The goal isn't to force them to know every single policy inside and out. Compliance is an open-book test, not a painful exercise in memorization. The aim is to make sure managers know what support and resources exist, when to use them, and how to find them.
Here’s what that could look like:
The goal: To build a foundational understanding of a new hire’s people-management responsibilities from an ethics and compliance perspective, with each concept building on the last.
The method: Short, targeted communications and training modules delivered over the first 100 days.
A sample 100-day training timeline for new managers 🗓️
This isn't about lengthy courses. Think short videos, checklists, conversation guides, and quick-reference job aids that point them to the right resources.
Day |
Topic |
Why a Compliance Focus? |
Broadcat Tools |
Day 1 |
Nothing! |
Don’t do anything. It’s the first day; they’re already overwhelmed. |
|
Day 15 |
Creating a Speak-up Culture & Handling Concerns |
This is the foundation. Managers must foster psychological safety so teams feel comfortable raising issues, and they need to know how to remain neutral and escalate when they do. |
|
Day 30 |
Wage & Hour Basics |
For managers of hourly employees, understanding timekeeping, breaks, and overtime rules is non-negotiable to prevent costly unforced errors. |
|
Day 45 |
Recognizing Accommodation Needs |
The ADA is nuanced. This isn't about making them experts, but about training them to recognize trigger phrases and knowing to escalate to HR. |
|
Day 60 |
Managing Conflicts of Interest |
COIs are often easier to spot at the team level. Managers need to know what to look for, how to disclose it, and how to manage the risk on their team. |
|
Day 75 |
Data Privacy & InfoSec |
Managers are guardians of data. They need to understand their role in protecting sensitive information, both for the org and their own team. |
|
Day 90 |
Preventing Retaliation & Fair Performance Management |
Performance management is a high-risk area for retaliation claims. This ties everything together by teaching managers how to give feedback that is fair, documented, and free from bias. |
|
Day 100 |
When to Reach Out to Ethics & Compliance |
The reach-out-with-any-questions message is peppered throughout these 100 days, but make it stick by emphasizing that the Compliance Team is always available for support and guidance. Then, clearly define when new managers should involve your team. |
Beyond 100 days: Reinforcing training when it matters most
Initial training is the foundation, but the real learning happens when it’s applied. The most powerful way to make these lessons stick is to provide just-in-time (JIT) guidance that’s triggered by real-world events.
Reinforce the training from the first 100 days by connecting with them in their moment of need. For example:
- When they open a new job requisition: Automatically send them a guide to fair hiring and interviewing.
- During performance review season: Push out the guide to fair performance feedback a week before reviews are due.
- If an investigation is opened involving their team: They should immediately get a guide on what to expect that reminds them about confidentiality and their critical duty to prevent retaliation.
This approach provides simple, clear guidance on what your people need to do to avoid risk, right when they need to do it. You can learn more about unleashing the power of JIT guidance and find more trigger events to build on.
It’s our job to make it easy
New managers are not a problem; they are our partners 🤝 in creating an ethical culture. But, we have to equip them for that role. By moving away from the "check-the-box" mentality and embracing a more thoughtful, behavior-based approach to training, we can turn a potential liability into one of our greatest compliance assets.
Bonus tip: Keep all these great resources in a dedicated manager resource library so they're easily accessible—and in one place—whenever a manager needs a refresher. You can find a step-by-step guide to building one here.
Bonus tip #2: Pair new managers with a seasoned manager for their first year as a short-term mentorship.