Right now, many people feel paralyzed and totally unmotivated.  This is reasonable.  As brain scientists explain in article after article, the news we consume and the uncertainty of this period freezes that higher-thinking parts of the brain, and we get stuck in cortisol-drenched fight-or-flight mode.  It’s easy to reach for the familiar and to try to stay the course with our programs moving as they are now.  But now isn’t the time for complacency.  Now is the time for the pivot.

If you have a yoga, guitar, or other type of teacher, chances are that person has pivoted their business to provide online services.  In response to the coronavirus crisis, most businesses have tried to find a way to have virtual or mail-driven service.  For example, some hairdressers are sending packets of the color they use on their clients to keep an income and to keep their clients looking fabulous.  A pivot is simply a turn or a change.  Business as usual can’t go on the same way it has, for you or for the businesses in your neighborhood.

Questions to Ask

The first thing to do is to consider all of the new or expanded risks facing the business.  Start with the following:

These questions should raise your awareness of the risks associated in the new business environment. 

Think Like a Criminal

Put yourself in the shoes of someone under immense pressure. 

Think about all of the ways the controls could be circumvented.

The Pivot

Once you’ve thought through all of this, pull out your annual program plan and pivot it to respond to these risks.  If you intended to update your anti-bribery policy, but new work-from-home policies are more pressing, shift your focus.  If you’d planned on visiting four countries this fall for in-person training, start calling eLearning vendors or companies that allow for webinar training.  If you’d planned communications around your gifts and hospitality policy in December, consider moving the communications calendar to send emails now emphasizing doing business in an ethical way consistent with the company’s values.

You should also pivot with respect to your communications with the C-suite and Board.  It is likely that the focus on ethics and compliance will be overshadowed by the coronavirus response.  Plan now to address that.  Remind the Board about the increased risk of fraud and bribery in times of recession/depression.  Remind them about the new data privacy and security risks.  Remind them of the dangers of aggressively moving into new markets or pushing sales at unsustainable levels on commission-only salespeople.  Remind them that the actions fueling prosecutions in two years’ time start now during a crisis.

Pivot your program plan to address the new needs of the business.  Rewrite your annual plan and submit it to your manager, C-Suite or Board.  Even if they don’t respond right away, begin the execution.  Being pro-active is critical.

Where should I not Pivot?

That said, you should not pivot when it comes to the core processes of your program.  For instance, this is not the time to stop your third-party due diligence program.  Consistency in such activities is key to maintain defensibility.  You should also not stop:

Pivots are necessary for entrepreneurs, businesses, and compliance programs.  By pivoting now, you’ll be facing the right direction when business gets back to business.