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Harry Cassin
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Crafting a company response to coronavirus: Six steps for doing the right thing

Coping with the coronavirus will require enhanced vigilance by compliance teams. As boards and senior executives navigate the way forward with a focus on sustainability and financial resilience, compliance officers must ensure they remain at the forefront and visible.

In a crisis situation there is a temptation to think that normal rules no longer apply. This is a mistake. In a post-Covid future that is currently hard to envisage, the virus will not provide any form of defense. Businesses, like governments, are already under considerable scrutiny for their response to the virus, with daily headlines to damn or praise. Our heightened awareness and the global scale of the crisis means that memories are likely to be long. How businesses conduct themselves in the coming months will matter in the long-term.

So how can compliance teams ensure that everyone in their organization understands that normal rules still apply? Here are six key steps that compliance officers should be taking now.

  1. Prioritize health and safety. This may take on new forms as many organizations are embracing new and varied working practices. Covid-specific measures should already be in place and those workplaces that remain open must ensure that social distancing can be properly implemented in order to keep staff fully protected. With the focus on virus-protection, health and safety teams may also want to ensure that the company’s usual health and safety standards policy still applies and ensure that teams continue with their usual monitoring. Mental health of employees will also be a heightened concern and may require human resources and health and safety teams to work together.
  2. Keep the code of conduct top of mind. Remind staff how the code of conduct applies especially during the current crisis. The code is designed to ensure that all the company’s stakeholders are treated fairly. Upholding the company’s values during this difficult time will be of vital importance in order to protect the business for all its stakeholders in the future. Remind staff of any golden rules and highlight any areas that may be high-risk for the organization. Keeping in touch and being visible is key.
  3. Conduct virus risk-mapping. Monitoring the spread of the virus globally and mapping that against existing risk maps for corruption and human rights issues will be important. Poor decisions are often made under extreme pressure so identifying where pressure-points might occur in already high-risk locations will help mitigate potential risks. Ensure that local compliance teams know that you understand their situation and offer additional resources and support where possible.
  4. Be aware of the increase risk of fraud. Governments worldwide are urgently taking measures to protect economies, including new loan schemes and direct employment subsidies as well as making rapid procurement decisions. Compliance teams should ensure that the correct processes are followed, that the company’s rules and values around integrity are upheld in applying for such schemes and that all actions are properly recorded.
  5. Keep abreast of any temporary suspension of regulation. In many jurisdictions, legislation may be relaxed temporarily to accommodate adjustments to working practices deemed necessary under the current situation. Competition rules have been relaxed in the UK to allow retailers to work together for example, and many European states have adopted a temporary relaxation of driving and test time rules to enable drivers to meet the current delivery demands. For global organizations a system should be put in place to monitor such changes and ensure that if implemented, they do not compromise the company’s own ethical standards.
  6.  Maintain contact with third parties and suppliers. Make sure all third parties are aware of your concern for their continued health and safety. Take steps to ensure that payment will be prompt – some companies are pledging to shorten payment terms to support cash flow. In higher-risk situations, suppliers should also be reminded that compliance with the company’s code of conduct is still expected and that any on-going monitoring will continue, if only remotely for the time being. This applies equally to any due diligence checks currently in hand. Online checks and virtual interviews are better than none.

The current situation presents an opportunity for businesses to do the right thing and many already are. For some this will involve direct help such as producing ventilators, sanitizers or protective equipment. For others it will be about acting fairly and responsibly towards all stakeholders during a time of unprecedented pressure. The steps above are a good place to start.

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