Flexibility is Key to E&C Teams Adapting to Pandemic: The E&C Pulse - September 9, 2020

September 9, 2020
Ben DiPietro

Sept. 9, 2020

Flexibility is Key to E&C Teams Adapting to Pandemic 


COVID-19 tossed the world on its ear, forcing people and companies to scramble to adapt to the ever-changing pandemic landscape. 


Some of the top-performing ethics and compliance teams are being flexible and innovative to maintain their program’s relevance and impact. 


This type of flexibility and adaptability is consistent with the main theme of regulators’ guidance; that the E&C program must be tailored to meet the organization’s risks and challenges, and not operate on “cruise control,” as the June 2020 update from the U.S. Department of Justice described it.


LRN’s Susan Divers recently led a Consero Knowledge Bridge panel discussion about adapting E&C training to remain relevant during COVID, and said despite the lack of face-to-face meetings, the human factor remains critical when it comes to meeting stakeholder needs, strengthening relationships, and having interactions.


“Taking a look as we emerge from the crisis, at what worked and what didn’t work, and making the changes you need to make to make sure you can meet and mitigate risks, I think is a critical takeaway,” said Divers.


An E&C executive at a global apparel company said he had recently finished building out his global team, which was out conducting in-person trainings, when suddenly, “everything had to just stop.” The team paused, and asked what was most important at this time. “If we were trying to do 15 things, we were encouraged to take it down to around five things,” he said.


Simultaneously, E&C was rolling out a code of conduct, which includes an attestation that all employees acknowledge they read the code. Instead of doing this from the network, the team delivered it to tens of thousands of people working at home. 


One of the things that really came out of this for him is the necessity of partnering with the corporate communications team. With some 75,000 employees in more than 50 countries, the company's executive team wanted to limit the amount of messaging, prompting E&C “to scale back and be careful about what we were communicating, and how we were communicating, so that we were all coming...with one voice.”


E&C tied its communications to the company’s three behaviors: acting like an owner, playing fair, and speaking up. “We really started focusing on behavior, and tying that behavior to whatever the message was at the moment,” said the executive. “We were reaching out to different cross-functional teams, realizing they were doing stuff, and were helping them bring out those behaviors to light, so that we were all kind of coming out of the one voice.” 


The CECO for a tech company said the biggest pivot for his team was, early in the pandemic, making the realization they needed to take a step back from some of the training initiatives they were pushing. 


“There was a lot of sensitivity to the new work-from-home environment, and we worked closely with our other stakeholders, like the corporate communications team, to be sensitive to the fact that our colleagues were going to be consumed and overwhelmed by a number of different emotions and challenges,” said the CECO.  


That gave the team time to support the company in ways outside of its core, such as in working to devise policies and processes for working from home, and for returning to the office when the time comes. “It was a real chance for our team to demonstrate that we truly are part of the team, that we’re not exclusively focused on ethics and compliance,” said the CECO.


A CECO at a holding company said one the silver linings from the pandemic is the teamwork that has emerged, what he termed “the we’re-all-in-it-together spirit.”


That has meant being nimble and flexible, and willing to help out where needed, because we’ve been asked to be involved in various items that are “not part of our ground game,” he said. 


E&C is being more hands-on with investigations it normally would delegate to other units, mostly human resources. With HR under duress during the pandemic, this executive said his team is handling more cases. E&C also paused on some of its ethics training and ethics-related communications. 


But with hotline call volumes down, when calls related to COVID aren’t counted, the CECO worries about what he doesn’t know. “We can handle any issue except the one we don’t know about,” he said.


“We have used the opportunity to build our reputation as the department that is collaborative and relationship-oriented, and I think that has helped us and has helped the company, and I think that will continue after the pandemic abates.”


                                                                                                        BEN DIPIETRO







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About the Author

Ben DiPietro

Joined LRN in October 2018 after 30 years as a journalist, including seven years at The Wall Street Journal, including Risk & Compliance Journal and was a creator of the WSJ Crisis of the Week column. In 2015 was named one of the 100 most influential people in business ethics by Ethisphere Institute. Spent 14 years as a reporter in Hawaii, 11 with The Associated Press.

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