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.
The full article will be available in the upcoming 2020 BELA South Asia Magazine.
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.