As I write, there is just over a week left of 2020 so I suppose I’m in a reflective mood. I won’t insult the reader by enumerating all the ways 2020 was a challenge, on every level; you know. You experienced them. But despite these challenges – and in some cases, precisely because of these challenges – there have been an awful lot of silver linings.
That was the main takeaway from a recent Ethisphere webinar moderated by my LRN colleague, Ty Francis. He was joined by Mia Reini, Senior Manager, Corporate Compliance & Enterprise Risk Management at Home Depot and Kristen Manney, Global Ethics & Compliance, Education & Engagement Manager at Oshkosh Corporation. Mia and Kristen discussed the challenges they and their organizations faced in terms of maintaining ethics and compliance (E&C) program continuity, adopting to a virtual world, ensuring compliance with every-changing regulations, and, most importantly, ensuring the safety of their front-line workforces. Here are their lessons learned:
Pivot, build relationships, and make it relevant
The E&C functions at both Oshkosh and Home Depot had to throw out – I mean, adjust – key elements of their program strategy for 2020. Site visits and in person training were no longer an option. Planned compliance topics for training and communication campaigns were superseded as InfoSec, social media, and respectful communications rose in priority.
Instead, Oshkosh Compliance engaged with business leaders to participate in and then cascade code of conduct training to their teams. Having business lines take the lead in communicating why this is important, especially when facing risks we’ve never faced before, resonated with employees: in less than 7 weeks, they had 99% participation, a significant improvement over recent years.
Home Depot Compliance was also proactive about reaching out to and engaging with the businesses. They invited themselves to 100 vice president staff meetings to do E&C refresher training; nearly all said “yes”. Using real examples that were connected to the COVID context made the training relevant, resulting in highly positive feedback.
Connect to company values
Home Depot’s response to the pandemic was to put their “values wheel” front and center. Their actions were not about driving sales, but rather ensuring employees’ and customers’ safety while supplying essential products. This meant limiting the number of customers in stores, closing early to allow for enhanced cleaning, implementing curbside pickup, and extending Black Friday to the whole month so as to reduce the typical crush of customers in stores. These actions and more, implemented nearly overnight, were seen as inherent to the company’s values of taking care of our people and doing the right thing, while still providing excellent customer service.
Oshkosh, starting with the CEO, looked to the company’s core values as the foundation for navigating the pandemic. They wove values into all company communications about COVID as well as social and racial unrest in a meaningful and authentic way. This wasn’t hard to do, as the company’s updated values seem tailor-made for this moment: we put people first, we do the right thing, we persevere, and we are better together. They also used the code of conduct refresh as an opportunity to reinforce the company’s values, and code trainings provided additional touchpoints to highlight how to bring values to life and live the Oshkosh Way.
Put people first
Although I’m recounting this lesson last, it was easily the number one priority for panelists. There is a reason why the taking care of our people “slice” of Home Depot’s values wheel is outsized relative to the other values; a reason why we put people first is at the top for Oshkosh. Both companies mobilized first and foremost around how they could keep team members safe.
Oshkosh established a cross-functional COVID team that met daily or sometimes even hourly, determining how to set up workstations to keep their production team members safe, how to source hand sanitizer amid global shortages, how to stay abreast of and in compliant with changing national and local laws in the 22 countries in which they operate. And Home Depot immediately made a number of significant changes to in-store operations, already highlighted above. Their compliance team sent the message that “we’re here to help” and attended every meeting they could.
Due to their customer bases, both Oshkosh and Home Depot are considered essential – Home Depot’s stores couldn’t close, Oshkosh’s factories couldn’t shut down. And, for a significant percentage of their workforces, this meant that people couldn’t work from home. As a token of their appreciation, both companies released powerful “thank you” videos for their associates and team members that made it all possible. Oshkosh likened the pandemic to a storm, reminding team members that “every storm runs out of rain…we will persevere, together.” Home Depot acknowledged “you were asked to rethink, redo, reimagine, and reinvent everything, and you absolutely delivered.” Perhaps it’s my pregnancy hormones, but both videos had me unexpectedly tearing up.
Mia and Kristen said some of the changes are here to stay. The forced shift to virtual environments and cross-functional teaming has accelerated the connectivity the compliance function has with the business. It’s also flipped the mindset that compliance is a challenge to business, to compliance is a partner in helping business happen in the right way. Seeing small children and dogs interrupt virtual meetings has made people more comfortable with the humanity we all share. Leveraging virtual platforms enables greater reach and frequency of communication that facilitates “just in time” ethics considerations. Keeping E&C content relevant to business audiences with “ripped from the headlines” examples ensures training is relevant, not rote. And, COVID has reinforced that compliance must be flexible, prepared to pivot as necessary. After all, there will be more crises, more unexpected risks. Home Depot and Oshkosh will be ready.
