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Right now, many people feel paralyzed and totally unmotivated.  This is reasonable.  As brain scientists explain in article after article, the news we consume and the uncertainty of this period freezes that higher-thinking parts of the brain, and we get stuck in cortisol-drenched fight-or-flight mode.  It’s easy to reach for the familiar and to try to stay the course with our programs moving as they are now.  But now isn’t the time for complacency.  Now is the time for the pivot.
If you have a yoga, guitar, or other type of teacher, chances are that person has pivoted their business to provide online services.  In response to the coronavirus crisis, most businesses have tried to find a way to have virtual or mail-driven service.  For example, some hairdressers are sending packets of the color they use on their clients to keep an income and to keep their clients looking fabulous.  A pivot is simply a turn or a change.  Business as usual can’t go on the same way it has, for you or for the businesses in your neighborhood.
The first thing to do is to consider all of the new or expanded risks facing the business.  Start with the following:
Are people now using their at-home devices to work?
Are people sharing or storing their documents in places unreviewed or not approved by information security (e.g., Google Drive, DropBox)?
Which people on your sales force are paid exclusively by commission?
Are we considering moving into riskier markets to try to get more market share or new customers?
What reputational risks are being created as the company pivots its own business model and procedures?
Is the company in a position to buy competitors or distressed assets (and if so, is compliance involved in the M&A process)?
Is the company furloughing or laying off employees?
Are people in your company working in countries with poor access to medical care?
What is the current timeline (if known) to ease lockdown orders in the countries and states in which your business does business?
These questions should raise your awareness of the risks associated in the new business environment.
Think Like a Criminal
Put yourself in the shoes of someone under immense pressure.
Is it possible to circumvent third-party due diligence procedures?
How would false expenses be entered into the system for reimbursement?
Where is there ambiguity in the policies and procedures that could be exploited?
Can training be avoided during the crisis?
In what ways can people communicate that can’t be tracked by the company?  What’s App?  Other chat programs?
Is there a way to draw up a purchase order (PO) without approval or control?
Think about all of the ways the controls could be circumvented.
Once you’ve thought through all of this, pull out your annual program plan and pivot it to respond to these risks.  If you intended to update your anti-bribery policy, but new work-from-home policies are more pressing, shift your focus.  If you’d planned on visiting four countries this fall for in-person training, start calling eLearning vendors or companies that allow for webinar training.  If you’d planned communications around your gifts and hospitality policy in December, consider moving the communications calendar to send emails now emphasizing doing business in an ethical way consistent with the company’s values.
You should also pivot with respect to your communications with the C-suite and Board.  It is likely that the focus on ethics and compliance will be overshadowed by the coronavirus response.  Plan now to address that.  Remind the Board about the increased risk of fraud and bribery in times of recession/depression.  Remind them about the new data privacy and security risks.  Remind them of the dangers of aggressively moving into new markets or pushing sales at unsustainable levels on commission-only salespeople.  Remind them that the actions fueling prosecutions in two years’ time start now during a crisis.
Pivot your program plan to address the new needs of the business.  Rewrite your annual plan and submit it to your manager, C-Suite or Board.  Even if they don’t respond right away, begin the execution.  Being pro-active is critical.
Where should I not Pivot?
That said, you should not pivot when it comes to the core processes of your program.  For instance, this is not the time to stop your third-party due diligence program.  Consistency in such activities is key to maintain defensibility.  You should also not stop:
The frequency of reporting to the Board
Having communications on ethics and compliance from the CEO/Top Management
Reviewing third-parties on a risk-based approach, even if this slows down contract approval
Requiring controls, like the gifts and hospitality registers, to stay in force
Audits of controls to ensure that the processes are being followed
Pivots are necessary for entrepreneurs, businesses, and compliance programs.  By pivoting now, you’ll be facing the right direction when business gets back to business.
Kristy Grant-Hart is a compliance and ethics expert specializing in transforming compliance departments into in-demand business assets.
UK Phone: +44 (0)203 514 1443
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