Ethical First Responders: An Interview with Tom Fox

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In the wake of Hurricane Harvey, in preparation of Hurricane Irma, and as wildfires rage through the Pacific Northwest, we are witnessing the heroic efforts of individuals across the nation. We are also seeing similar efforts from local and national organizations playing their part to stabilize affected areas. Is this rolling-up of the sleeves of ethical first responders just an incidental result of being in the wrong place at the right time? Or is it the result of some form of ethical inertia emanating from purpose-driven organizations?

To get a better idea, I talked with Tom Fox, the Compliance Evangelist, and Houston Texas resident.

  1. Both inside an organization and out, what does ethics and compliance look like in the wake of a disaster?

Ethics and compliance in an organization looks the same in a disaster as it does in non-emergency situations. If a company is doing ethics and compliance by operationalizing it into the fabric of the organization, it will be able to do so in the wake of a disaster. If it has only a paper program, it will have no chance to engage its stakeholders through ethical behavior or through compliance during a disaster.

  1. We’ve been seeing a lot of media around organizations leaning in, or leaning out, in the wake of Hurricane Harvey, and in preparation of Hurricane Irma. Does an organization’s response during a state of emergency say anything about its ethics, culture or core values?

Yes it does. If a company takes steps to help all its stakeholders including customers, employees and third parties, it is only because those values were burned into the DNA of the company through preparation and practice.

  1. As a Houston resident, how have ethical first responding organizations played a part in supporting your community?

These companies jumped immediately into supporting roles that demonstrated not only ethical behavior but also showed how creative businessmen could use their organizations in ways perhaps different than their commercial focus. 

Those companies which had a plan in place – which were prepared and had practiced that preparation – were ready to jump in on literally a moment’s notice to respond as soon as they could access the affected areas of Texas. These companies jumped immediately into supporting roles that demonstrated not only ethical behavior but also showed how creative businessmen could use their organizations in ways perhaps different than their commercial focus. Two examples – Gallery Furniture has a huge furniture emporium so it opened up its flagship store as a refugee center. HEB Grocery became a logistics company delivering much more than food to those in need because of its superior transportation system.

  1. Companies living into their corporate social responsibilities are getting noticed in a good way. When it comes to contributing to a greater good, is there a distinction between ethics and brand building?

There is no distinction between ethics and brand building. Put another way, your organization’s brand is its ethical behavior. People remember commercial entities that cheated them, treated them unfairly or simply did not respond to their needs. Further if you company engages in such unethical practices such as price gouging during an emergency such as Hurricane Harvey, it will destroy customer confidence in your organization for a long time down the road.  


Read More: Can Marketing and Compliance Share a Playbook?


  1. Is an organization’s disaster response a job of the compliance department? If not, does compliance play a role? If so, what?

The role of compliance starts long before a catastrophe hits. The role of compliance is to help plan, prepare and practice for an emergency. The compliance department then needs to make sure that employees on the front lines are empowered to respond to the emergency as they see fit due to the circumstances on the ground.

  1. Since natural disasters don’t really give us a schedule to plan around, how are organizations able to respond quickly to a need in a meaningful way? Does this vary depending on the size of the organization?

It all comes down to being prepared. But preparation is more than simply having a written plan in place. The single most important lesson from Hurricane Harvey for the compliance professional is to practice your preparation plans. Test your emergency hotline. Make sure all contact numbers for the compliance department, C-Suite and board members are current, up to date and are working. Test your communications system literally across the globe by practicing an emergency situation. Make sure you have communications and data secured and backed up.

Download: Four Key Board Responsibilities for Monitoring Risk and Compliance


What do you have to say? Share your thoughts in the comments below or join a discussion group on Compliance Next.


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