“The easiest period in a crisis situation is actually the battle itself.
The most difficult is the period of indecision -- whether to fight or run away.
And the most dangerous period is the aftermath.
It is then, with all his resources spent and his guard down, that an individual must watch out for dulled reactions and faulty judgment.”
~Richard M. Nixon, 37th President of the United States
As a Chief Compliance & Ethics Officer, you know that the eventuality of crisis striking your organization is not a matter of “if”, but only of “when.” You spend your career crafting and implementing a governance system of policies & procedures, training, monitoring, and reporting whose value will ultimately be assessed in those moments and days following the crisis. Not all systems (nor all leaders) will survive the test.
Crisis will not politely schedule an appointment with you on a lazy afternoon, but will more likely descend upon you furiously, publicly and embarrassingly at the most inopportune of moments. Crisis will arrive in the guise of a viral tweet, a regulatory inquiry, or a criminal indictment. A loyal staffer will hesitantly summon you from a meeting into the hallway to advise you of the breaking news. And so begins the moment of decision.
As Compliance leaders we have trained our entire lives to guide and protect our organizations from harm. The very same principles that we have employed to prevent and mitigate risk will come into play when we must navigate our organization, its leadership and its board through and beyond the crisis. Decisive action that engenders trust must remain at the forefront of the response.
Thus, together we must continue to:
- Act ethically and decisively;
- Communicate frequently and transparently; and
- Modify practices appropriately.
Act ethically and decisively
Crisis does not represent your organization in its entirety. Your mission, your values, and your people remain fundamentally sound, even when something has gone awry. Therefore, even as you and your leadership team are undertaking an investigation and crafting a response to the statement, incident, or charge, you will continue to direct your employees to perform their day-to-day responsibilities with the accustomed level of adherence to ethics, compliance, and mission-focus. Your organization will survive the crisis, and so the continued service to your employees, clients, customers, vendors and shareholders must remain highly-functioning.
Communicate frequently and transparently
Do not compound the temporary negative impact of a crisis by shrouding the crisis in a cloak of shame and secrecy. While not proud of the event that has triggered the crisis, you remain nonetheless committed to your employees, your customers, your brand, and your mission-focus for the long run. Within that long view context, communicate quickly that leadership is:
· aware of the situation;
· taking it seriously;
· cooperating fully; and
· is committed to resolving it.
Convey that future communications will follow as additional information becomes available, and adhere to that pattern, even if only limited information becomes available. Your stakeholders are better served by hearing the truth from you, than the mistrust that will take root if they begin to receive their information—accurate or misconstrued--from external sources.
Modify practices appropriately
While some crises will end with a conclusion that the crisis was merely malicious and unwarranted, often the investigation will reveal a compliance or control weakness that must be addressed by your organization. Once identified, own both the root cause and the solution, communicating the same to your stakeholders. Then set to work implementing the required changes that will ensure the situation has been appropriately addressed. If additional training is warranted, then make every effort to involve the affected employees in designing and testing the training before it is rolled out to the larger audience. Schedule subsequent time to review the modified practice and test its effectiveness, regardless of whether required to do so by a regulatory body or not.
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Crisis will erupt. You will be called upon to act in the best interest of your organization and its stakeholders. If you have prepared yourself, your leadership team, and your board in advance of this moment, then you will pilot your organization to a brighter tomorrow with the flag flying high. Otherwise, armed only with dulled reactions and faulty judgment, you will find yourself waving the flag of surrender.