The Role of the Compliance Officer in the Post-Pandemic Roundtable

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Michelle Nichols, Chief Compliance Officer | VP of Diversity & Inclusion | Exec Leader of People Strategy | #ONO (Open to New Opportunities)

“Were we true to our core values?”  This question is probably not on many organization’s transitions to a normal checklist in their Business Continuity Plan. Following the pandemic, business leaders will gather to review how their organizations responded to the crisis and will convene a roundtable of leaders to review their actions.  Discussions will ensue around policies and procedures and their adequacy; other talks will be focused on supply chain disruptions, finance and accounting practices, employee communication effectiveness, and work from home strategies. 

What will likely be missing from these meetings are discussions about whether the pandemic response demonstrated the company’s culture and lived its values as outlined in its Code of Conduct. Challenging times are when corporate values are the most helpful as they provide a roadmap for ethical and compliant behavior. Assessing this aspect of the incident response is just as important as the business questions. This is where the Compliance Officer can make the biggest impact on their role. Here are three steps to gather feedback and discuss the organization’s response as part of this debrief. 

Collect Feedback

Compliance professionals are experts in demonstrating program effectiveness.  We collect feedback as part of our compliance management system processes.  Those same protocols should be used to determine pandemic response effectiveness — and it begins with asking targeted questions. 

Survey Employees:  A quick and easy way to gather feedback is through a survey.  Questions asked should revolve around the core values and demonstration of those values in times of crisis.  For example, if your organization has a core value of treating everyone “with dignity and respect” — you need to determine if in fact, this happened.  Survey all of your current and former employees; even those who may have been laid off or furloughed as part of the incident response.  Survey your leadership team independently for their candid feedback.  Challenge your leaders to critique their own actions through a cultural lens and not simply a business lens.

Survey Customers and Third Parties:  The goal for this survey is to find anecdotal data as to how they believe the organization demonstrated (or failed to live up to) its core values during their interactions.  Ask for specific examples as to how they believe the organization showed empathy and respect during this difficult time.  Ask what could have been better or seek suggestions for improvement.

All survey questions should have both a numerical (1-5 scale) rating as well as a method for capturing typed feedback.  If you have employees that require the survey in another language, it should be translated.  The survey should be short and be administered as quickly upon return to normal as possible so that the examples are timely and relevant.  Once you have collected feedback, you will need to commence with a review.

Review the Feedback

Some of the responses may be tough to read.  Lives may have been altered significantly as a result of the organization’s decisions.   You might also have business leaders who respond, “We did what we needed to do to save the business.”  If the business you are saving does not live its culture and values, what does that say about the culture of compliance required to ensure your program is effective? 

Evaluate the unique survey responses (employees, customers, third parties) independently as it will help in action planning. Make note of similarities in the data as well.  The feedback from laid off or furloughed employees should be reviewed separately from those who remained working.  Did you communicate enough with both of those groups that you could answer an unequivocal “yes” that you upheld that core value? What about your customers? If you collect customer and other third-party feedback, evaluate that feedback as a way to measure adherence to your core values.  Did you treat your customers as outlined in your Code? Did you maintain your recognition programs despite the lack of employees or did it fall by the wayside?

Don’t forget to also evaluate your hotline calls during this same time period.  Combine the data from the hotline with your employee feedback as some may not complete the survey because they called the hotline. Now that you have captured and reviewed the data, you will need to prepare lessons learned presentation and determine the next steps.

Lessons Learned

So, what did you learn?  What will you do with that information?  At the very least, it should be shared with your executive leadership team along with your suggestions for improvement and changes.  Remember to celebrate those areas where your employees and customers thought you did well and recognize those employees who contributed to that good feedback.  Develop a plan for addressing the opportunities and get your leadership on board with your go-forward plan.  Augment your business continuity plan so that this type of analysis is commenced following any incident as a normal response and recovery process.

Keep in mind, as you resume your hiring processes, candidates will rightly ask how the organization responded to the crisis.  You will need to develop talking points for the talent acquisition team and hiring managers to adequately respond to that question.  It may be the difference between a candidate accepting an offer and one who does not.  If you can honestly talk about the assessment you did and the changes you made to enhance the employee experience going forward, you may sway the candidate.

The post-crisis roundtable is a perfect opportunity for a Compliance Officer to shine! Use your skills for ensuring program effectiveness and apply it to living the values. The outcome can only seek to enhance the role of compliance and further demonstrate program effectiveness going forward.

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Michelle Nichols

Michelle Nichols

Michelle Nichols is an experienced, passionate leader in the Ethics and Compliance space. She has spent the last 20 years as both an in house practitioner for two large organizations...

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