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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
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Bill Waite
Contributing Editor

Russell A. Stamets
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Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

At Large: No toilet paper? That reminds me of the compliance department . . .

In Newport, Oregon, police are asking citizens to stop calling 9-1-1 to report that they’ve run out of toilet paper. The UK’s sewage system is in danger of clogging from wet wipes and other improvised loo roll substitutes. In Paris, PQ panic has set in, as papier cul (excuse my French) has disappeared from stores everywhere.

What’s going on? And what are the lessons for compliance professionals?

1. Fear produces irrationality. There’s enough toilet paper for everyone. We know that because every day for years we’ve all had enough. But when uncertainty about Covid-19 set in, people started imagining things. Like a world without toilet paper. In our work, then, what happens if we think the future is shaky? What if we fear losing our jobs, or being demoted, or having our pay cut? Might that fear motivate us to pay a bribe? Even if a bribe may not work, is always illegal, and is likely to end in disaster for us personally, might we pay a bribe anyway? Oh ya.

2. Fear looks just like greed. This is a familiar topic for compliance professionals. Is the problem compliance programs are trying to solve fear or greed? From the run on toilet paper, it’s clear that fear is often a starting point. I was in Costco early last week, looking for potatoes and vegetable juices. What I saw were hundreds (thousands?) of people with shopping carts full of toilet paper (and diapers and water). They looked greedy. But my wife reminded me that they were scared. My empathy for them returned and I understood the scene better. Compliance officers with empathy have a big advantage in diagnosing and treating what might make their company sick.

3. When we’re stressed, we do what we’ve practiced. Most people have been through severe weather. We know what happens. The power goes off, streets are flooded or otherwise blocked, phones don’t work. It’s dark, lonely, and frightening. For that type of emergency, we know how to get ready and how to respond. We buy toilet paper, diapers, and water. Batteries too. So when Covid-19 became an emergency, we did what we know. We acted as though it was a natural disaster. Are we stupid? Not at all. In times of stress, people always do what they’ve practiced. That’s why police go through endless scenarios with role-playing. Over and over again. So that when the real thing happens, they’ll react in the way they’ve trained. A compliance program, then, should do the same thing. It should train people to react to stressful situations (demands for bribes, for example) in the right way.

4. Prepare for the unexpected. Could any reasonable person have predicted this toilet paper shortage? Maybe. But I didn’t see it coming. What’s the lesson? We don’t know everything, and we don’t know what we don’t know. Life brings surprises, and some are unpleasant. As Arnold Toynbee or Churchill or someone allegedly said, “History is just one damned thing after another.” Once we understand that, we can start equipping ourselves and others to handle those “damned things.” Maybe the last line of defense isn’t only a written plan, but also something much deeper. Maybe compliance, finally, owes more than we think to human relationships. If the sales and marketing folks like and respect their compliance officer, can that change what happens, as much as any plan?

5. Perception is reality. To repeat, there’s enough toilet paper in the United States, the UK, and France for everyone. The “shortage” only appeared when people believed there wouldn’t be enough to go around. So perception became more important than reality. The compliance lesson? If people believe they have to pay bribes to win work, they’ll find a way to pay bribes. The expectation of corruption will eventually produce corruption. What then? Compliance programs need to teach people not just a set of policies and procedures, but also how to think differently. Countless companies have already learned that bribery isn’t necessary for business success. Helping people believe that is what’s needed. Telling stories about how “clean business is good business” is therefore a hugely powerful compliance tool.

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  1. Don’t excuse your French. You have the correct expression. It is ridiculous, so it makes us laugh about a ridiculous comportment. Thanks for the point-de-vue!

  2. Very relevant article at this time

  3. Hey Richard. And I thought that was an exclusive freakin behavior from Brazilian people (about toilet paper).
    Very insightfull article.

  4. Right on the money. I’m in Johannesburg where we’re in a nationwide lockdown that only started at midnight (about 15 hours ago), and toilet paper has disappeared from the shelves, before lockdown commenced. As one parody video clip expressed, “we can’t understand it – Covid-19 is a sickness of the lung, not the bum!” Hand sanitizers disappeared too, never mind that soap and water does the job better – irrational fear, and greed too since some are now selling their stocks on street corners at exorbitant prices…

  5. Very relevant article… I am writing from Malawi, most of our imports come from South Africa, and when South Africa announced a lock down, everyone went into overdrive buying “essential’ unfortunately, business owners have also taken this opportunity to inflate the prices of “essentials.”

  6. Here in Nuevo León, Mexico, the first cases in our state were all concentrated in the wealthiest municipality–imported, of course, by travelers. Shortly after the first case was announced, Costco and other stores that cater to the relatively wealthy suffered panic buying, but the stores frequented by the less elite experienced less difficulty keeping up inventories. Is there a class-based lesson on bribery here?
    I think this speaks to your final point: perception is reality. Many in the lower classes have followed our president’s lead (similar to Trump’s), that life goes on, and should continue normally. The more highly-educated here rejected the president’s claims and self-isolated before being exposed. But the voice (and behavior) of a leader can influence perceptions and, thus, other people’s behavior.

  7. Great post, Dick. Indeed, fear can look a lot like greed, and I need to remember this when people act irrationally and dramatically right now. We have no idea how to process the information we’re hearing while executing the actions we’re told to take — actions that are annoyingly liberty-stripping, yet crucial for our well-being. (“I’m American! You can’t tell me I can’t hang out in the park with my friends.”) I hope we can be patient with each other.

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