“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…
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