Protecting colleagues and their families has always been an important objective of compliance. As coronavirus continues to shake the world to its core, it is essential to address how compliance officers can support their organizations according to global legal and safety requirements.
Author: Hernan Huwyler, governance, risk and compliance specialist for multinational companies
Declared a global emergency by the World Health Organization, coronavirus raises challenging issues for employers—particularly those with multiple services, locations, and a global workforce that travels regularly. For employers who have lived through prior global pandemics, it’s time to revisit protocols by re-reading, re-evaluating, and adapting them to different areas of operation and evolution in local laws.
Managing the impact of coronavirus largely falls under the responsibility of compliance officers. However, management isn’t drastically different from other corporate pandemic response programs such as H1N1 influenza and SARS. This article provides five tips for compliance officers to support their organizations in dealing with the disease.
1. Maintain the confidentiality of affected employees
To comply with anti-discrimination requirements, the identification of infected or suspected-to-be-infected employees should be kept as confidential as possible. Compliance officers should make sure to reinforce the organization’s confidentiality policies with line managers and HR staff. In addition, general communications should not link the infection risk to people wearing facemasks or to any specific country or race.
2. Encourage sick leave
Even at early stages, employees exhibiting influenza symptoms such as a fever or cough should be told to stay home. This requirement should also extend to family members and other cohabitants to reduce the risk of the disease spreading further. Following international and national official guidance, compliance officers should also temporarily waive sick leave and pay policies to allow employees to remain at home for self-quarantine, even when official medical documentation is not submitted.
3. Limit travel and business meetings
Traveling from and to high-risk areas such as China, Iran, and Northern Italy should be limited or only allowed on exceptional occasions when official high-level approval has been issued. Video conferences provide a practical alternative to face-to-face business meetings, particularly large ones. Compliance officers should ensure that changes in the coverage of travel insurance are communicated, as well as government travel and hearth alerts and restrictions.
4. Protect employees, contractors, sub-contractors, and visitors at higher risk
Preemptive measures such as wearing appropriate personal protective equipment including respiratory protection should be reassessed in light of coronavirus threats. Likewise, compliance officers should ensure that good hygiene practices in the workplace are updated, communicated, trained, and monitored effectively to comply with the duty of care towards employees and third parties in general. For example, the disinfection of common areas and shared items should be undertaken frequently.
Employees with critical functions should be identified to ensure that they are able to work from home or other locations if necessary. Finally, the reporting of certified cases and countermeasures must be agreed upon with vendors and suppliers in compliance with contract clauses. Having a single point of contact to address issues related to coronavirus is an effective measure to facilitate consistent communication and ensure everything possible is being done to prevent the spread of the disease.
5. Understand the legal impact of interruption to operations
Wider changes related to labor practices should involve unions and employee representatives. Regarding each individual organization, compliance officers should balance legal requirements with response actions to ensure safety comes first. This requires revisiting and confirming contract, labor, and salary requirements in the event that offices, facilities, and plants are closed in a pandemic.
Hernan Huwyler, MBA CPA, is a governance, risk and compliance specialist for multinational companies. He works in developing internal controls to address business risks and legal requirements in European and American corporations and is currently the Head of Vendor Compliance and Due Diligence – Center of Excellence Danske Bank. He previously served as Risk Management and Internal Control Director for Veolia, leading governance practices in Iberia and Latin America. Hernan frequently lectures on compliance, risk management, data privacy, GDPR and auditing at top universities and business schools. Follow Hernan on Twitter @hewyler
Note: The views expressed by the author of this paper are completely personal and do not represent the position of any affiliated institution.