Business Integrity Lessons from a War Zone for a World in Pandemic

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Post By: Nadine Tushe, JD, CAMS, CGSS

From 2016-2018 I worked for the United States Agency for International Development (USAID), the U.S. government agency charged with providing aid and humanitarian assistance to vulnerable populations abroad. While my colleagues worldwide were promoting sustainable agriculture and distributing mosquito nets to combat malaria, I had a less obvious job: to recommend a response when these high-minded endeavors went terribly wrong, as part of USAID’s administrative sanctions function.

My time at USAID was defined by the Syria crisis. Refugees streamed across the borders of neighboring Turkey and Jordan seeking safety as Aleppo was reduced to rubble. The U.S. Government, along with other national and international agencies, tried to ease the suffering with purchases of basics like soap, blankets, frying pans, and lentils for the people displaced.

Many of us engaged in this work were surprised to see that the physical danger and political volatility of the conflict zone were not the only obstacles to carrying out humanitarian programs. Millions of dollars pouring into what had been small, local markets in border towns provided an opportunity for the darker part of human nature. Corrupt individuals at local vendors and multiple reputable, international Non-Governmental Organizations (NGOs) seized the moment for price-fixing, bribery, and product substitution, resulting in fewer, lower-quality items getting to the populations in such desperate need of them, not to mention reputational damage for the organizations involved.

I was emotional at times as I first processed that there were people in the world who would try to profit from making a refugee family’s food kit a little lighter or their child’s jacket a little thinner. But the shock gave way to a pragmatic understanding that there are certain challenges posed by rapidly changing conditions and emergencies, and practical steps that can be taken to mitigate these risks.

In 2020, of course, volatile conditions and emergency procurements can occur much closer to home. Our crisis in the United States may be quieter, and slower than Aleppo’s, but certain elements—the sense of urgency and disruption, the limitations of travel for safety reasons, and the outpouring of cash for reasons previously unanticipated—are familiar. So while you protect yourself, your family, and your work team from coronavirus, here are some practical lessons for protecting your enterprise from that other sickness, corruption.

  1. Have specific procedures in place for emergencies, and revisit these periodically. Have new remote work arrangements made you less than compliant with your usual procedures for, say voucher authorization or inspection of goods received? A common practice among organizations providing humanitarian relief was to have designated, streamlined “emergency procedures” for situations requiring rapid response. Make sure, however, that you define what constitutes an “emergency” and ensure that such procedures are not overused. If you’ve been missing key signatures or forms for the past eight months of pandemic, it’s time to revamp your policies and procedures for the new normal.
  2. Beware of quality issues as demand for certain products surges. From PPE to the more mundane items for life at home, the market is struggling to keep up with our changed needs, and creating opportunities for those who would take advantage. This can range from outright fraud to gray areas of product quality, as anyone who has ever overpaid for a disappointing item on Amazon knows. Bottom line, do your due diligence when procuring items in high demand, from plexiglass to personal fitness equipment.
  3. Build practical “redundancies” and quality checks into your organization’s procedures. Don’t let fewer people in the office become a chance for bad actors to fly under the radar. For example, can inventory be conducted and verified by multiple individuals on different days in the office? If the usual responsible party cannot make it to the job site for health reasons, can you collect data from other local stakeholders? If there is not one individual that you trust, consider using an amalgamation like survey data.
  4. Think about compliance now, not later. Cutting procedural corners in the name of urgency and survival may seem like common sense to some, but in my experience it can create long-lasting damage to an organization’s integrity. Use the crisis as an opportunity to build agility—to finally make that leap to electronic files or develop an app to deliver training modules. Integrate a culture of accountability and record-keeping into your pandemic procedures, leveraging technology to ease the process where possible.

Americans have woken up to the notion that public health is not only a concern for developing countries; the same can be said of corruption. In this time of upheaval and rebirth, we would do well to guard our business integrity as assiduously as we do our health.

About the Author: Nadine Tushe is the Founder and Principal of Luminary Compliance Counselors, a legal advisory firm. Views are the author’s own.

3 COMMENTS

  1. thank you Ms. Tushe–well said and something that we have to constantly keep in mind. Good people can do something wrong in the face of “urgency”. Carolyn

  2. Thank you for this eye opener, it makes sense to keep in mind where we can do wrong to others and where others can do wrong to us.

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