Concrete Ways to Be a Compliance Leader in a Time of Crisis
/“It looks like the start of a zombie apocalypse movie today in Los Angeles,” my friend Jeremy wrote on Facebook. If you feel like the world is ending, you’re not alone in that sentiment. But in a time of crisis, Compliance leaders must keep calm and compliance on. Compliance personnel must be leaders and show strength in this time of upheaval, whether they feel like it or not. But what does that mean in practice? Here are some concrete ways to be a compliance leader in a time of crisis.
1. Re-assess the Risk Facing the Business
For many employees at your company, this is a disorienting time. People who’ve never had to work from home before are suddenly finding themselves at their kitchen table with a laptop – often with children running around whom they’re supposed to be home-schooling while working. For some businesses, the drop in revenue will be precipitous, especially if the business is in a US state or a country where “non-essential businesses” have been shut for the upcoming weeks. Many salespeople can’t make sales calls. Hourly employees may be left immediately without an income.
As the saying goes, “Desperate times call for desperate measures.” Desperate measures, based on short-term thinking and panic, must be contained as much as possible. To get in front of this kind of thinking, perform a mini-risk assessment to consider places in the business that may be in particular danger, then think about what can be done now to mitigate that risk.
For instance, if the sales employees can’t make sales calls, consider asking management to reduce the numbers required to hit bonuses this year. Understand that people may be trying to push contracts through immediately without concern for the compliance terms, or get third-parties on board without the rigor of due diligence. Intervene where you can and audit the third-party requests more carefully. Some people may be de facto bringing their own devices to work because the infrastructure to work from home hasn’t been developed. If people are using their phones for work communications, send a reminder of the privacy policy to blunt the impact. Be prepared with a response, and vigilant to see that processes are followed.
Put additional safeguards in place where necessary. By taking a pro-active approach to risk response, you’ll save the business fallout later this the year, and in years to come.
2. Don’t Believe that You’re Immune to Rationalization and Short-Term Thinking
Richard Bistrong wrote a wonderful column this week about his own experience with sunk cost fallacy and the short-term thinking. Many months ago, Richard and I planned a dinner for several clients that would take place during the Amsterdam SCCE conference, which was scheduled to happen this week. I was scheduled to speak at the conference. Nine days before the event, I came down with a mild cold. I had been to Europe recently, but the outbreak had not begun in earnest. The explosion had just started in Italy, and I had not been in Italy.
I struggled long and hard with whether to cancel. Even though I knew that there was the possibility that I had been exposed to the virus, I began to rationalize. I felt conflicted – I had so many clients coming to our dinner, and I would be letting them and Richard down if I didn’t go. Plus, I was scheduled to speak and might have to step in if another speaker couldn’t attend the conference. And I am on the Board at the SCCE, so I should be at the conference to represent the organization, plus my cold wasn’t that bad… It was easy to rationalize and harder to do to the right thing than I’d like to admit. In the end, I canceled 48 hours before the conference was canceled.
In our field, we study human behavior. We know the cues and how rationalization works, but it is easy to have blind spots when it comes to ourselves. Be vigilant in scrutinizing your own thinking. Look for short-term thinking, rationalization, sunk cause fallacy. It’s easy to fall victim to these things at a time like now.
3. Act Calm – Even if it Is an Act
As hard as it is, this is the perfect time to practice acting “as if.” Acting “as if” is the skill of taking on the movements, breathing, physical stature, and thinking of someone who is calm and able to make rational decisions. This will help you to remain decisive, as well as respond to business concerns quickly.
This advice does not mean you don’t feel the fear or empathize with people who aren’t handling the situation well. It does mean you take your fear away from the employees you’re here to serve.
4. Expect to Take a Back Seat for the Moment, But Check in Regularly with Leadership
It’s a sad truth that we must face. When a crisis like this strikes (as opposed to say, a regulatory investigation), compliance is likely not top of mind for the C-suite and Board. We may need to take a back seat at the moment, but don’t let that stop you from checking in at a regular cadence. You want to stay in front of leadership, and let them know that you’re here to help.
5. Get as Much Done as Possible to Prepare for the End of the Crisis
If you find yourself with time because leadership is otherwise occupied, use the time effectively. Write an outline for the annual ethics training, draft the trade sanctions policy, or create the Supplier Code of Conduct. Do the work that can be done now so your projects can be quickly deployed once the crisis has finished.
6. Use this Time to Learn
In addition to prepping the work that can be prepped, take this time to learn new skills. Invest in yourself. Read Compliance and Ethics Magazine or Compliance Week. Attend the HCCA/SCCE webinars. Listen to compliance-related podcasts. Or, if you’re new in compliance (new, one or two years in the industry), take the Wildly Effective Compliance Officer Newcomer Course (information HERE). Read the Compliance and Ethics blog.
If you’re working from home, these activities will help you to feel connected to the broader compliance world, while giving you skills and knowledge that will further your career when this time of worry has ended.
We don’t know how long this pandemic will last, but we do know that we need to show leadership in the face of upheaval. By keeping calm and compliance-ing on, we will show our strength and necessity to our organizations.
