The global pandemic has forever changed our experiences―as customers, employees, citizens, humans― as a result, our attitudes and behaviors are changing.
These are difficult times for most companies across the globe, bringing with them a completely different set of challenges and risks. Situations like these often-become breeding grounds for corruption and fraud. It is important to keep in mind that when the times get tough— some companies tend to prioritize business objectives over compliance requirements.
If there is one lesson to be learned from the past crises, it is this: once the situation gets back to normal, governments around the world come down heavily on companies that have taken advantage of the crisis by compromising their core values. Leaders need to be mindful of any deviation—inadvertent or intentional—and prevent the current crisis from become a compliance crisis.
The current global situation, particularly in the light of new operating models such as remote working, poses similar risks to organisations. Companies should consider retooling and re-evaluating their compliance policies, especially their anti-bribery and corruption compliance programs.
Doing the Right Thing
At Honeywell, we are constantly encouraging employees to be mindful of their actions and their impact on the organisation’s reputation. We remind employees that Honeywell’s values are non-negotiable and that they should continue to do the right thing and follow the principles of our Code of Business Conduct in times of crisis, perhaps more than ever. The company’s philosophy is not malleable. It is written in stone.
From an anti-bribery and corruption perspective, specific areas to watch out for during these trying times include:
Controls and approvals: It is imperative that companies put in place additional compliance controls and approvals for all kinds of charitable donations, sponsorships, and outflow of anything of value. Like with most organisations, Honeywell is receiving increased requests for donations, particularly—but not only—for personal protective equipment (PPE). The company philosophy is clear: life-saving equipment that belongs to the frontline should go to the frontline. Employees have been asked not to make independent decisions but to engage with the Integrity and Compliance teams and gain their support before offering anything of value to anyone, especially if it involves state-owned enterprises and government organisations.
Internships and recruitment: All employees are asked to be mindful of entertaining requests pertaining to internships and recruitment. Opportunities for university students to gain work experience abroad have decreased in the past few months, and many companies in India will see a surge in requests from customers for internships for their family members. The guidance is clear: everyone needs to go through the standard recruitment channels, and any individual nominated by a government official additionally needs to be screened and approved by the Integrity and Compliance and Legal teams. Employees need to understand that we do not give special treatment in the current circumstances.
Third-party risks: Channel partners or third parties continue to remain one of the most significant anti-corruption risks for any company. At Honeywell, we articulate the need to exercise heightened vigilance during these times to ensure that no third party is engaged without thorough reputational and background screening, anti-corruption training of the third parties, and adherence to relevant clauses in agreements.
Communicate. Enable. Empower.
So, are we doing anything differently?
There is a constant endeavor to reiterate and reinforce the organisation’s commitment to anti-corruption compliance by communicating the importance of good governance to employees and stakeholders coming right from the top. It is imperative to ensure that there are refresher training and leadership communication on policy requirements and laws for employees, depending on the risk profile.
Further, it is important for senior management to let employees know the company’s position on misconduct that might have occurred, as well as to highlight incidents of employees standing up to bribery demands, which make great examples of setting a culture of compliance and emphasizing a commitment to compliance and ethical conduct.
The need of the hour is for organisations to adequately empower their employees with digital tools and make processes simpler and easier to navigate while seeking approvals for business courtesies, gifts, and engaging third parties. Quicker processes ensure employees start viewing compliance not as a roadblock but as a competitive advantage that will put them and the company ahead of the game.
Last but not the least, organisations must encourage employees to report wrongdoings or voice concerns without fear of retaliation. At the same time, the larger compliance teams must be empowered to respond to concerns in an appropriate and timely manner.
The Right Way Ahead
Companies should continue to build and promote their reputation as ethical organisations. The benefits of a such a reputation extend well beyond merely avoiding compliance issues, to include improved financial performance, higher employee morale, and organisational stability. It will also help attract higher-quality employees.
In the end, there is no panacea when it comes to fighting bribery. Companies should consider all options, depending on the region and country where they are based.
About the Author:
Piya Haldar is Director of Integrity and Compliance at Honeywell India. Haldar has held this role since 2015 and she serves as Honeywell India region’s Compliance Officer for all businesses of the company in India, which has close to 15K employees. She is also responsible for tailoring and driving a risk-based compliance program at the company (including FCPA/Anti-corruption programs to adapt to regional requirements). In 2019, Haldar received Honeywell Corporate, USA: Gold Award for “Being Courageous” (Global). She previously held compliance roles at GE and American Express.
