Disruption from coronavirus is no longer theoretical. As COVID-19 spreads, schools and businesses are shutting down and social distancing, even sheltering in place becoming the norm. Financial institutions are working to ensure continued access to financial services despite these conditions. To do this effectively, they need to assess and manage the operational risk presented by the coronavirus.
Operational risk is the risk of financial loss when processes, people or systems fail. The goal of assessing operational risk is to increase operational resilience—ensuring there are procedures to identify, assess, and mitigate reasonably foreseeable internal and external risks.
Assessing operational risk requires the cooperation of every department and business line. In this series of articles, Ncontracts will address key operational risk considerations department-by-department to help your FI with pandemic preparedness & business continuity planning to strengthen operational resiliency.
We’ll begin with human resources.
It’s no secret that the ongoing pandemic is creating unprecedented disruption to the workforce. Many HR departments are scrambling to keep pace with an evolving environment, working to make sure the FI’s human capital is protected and that the rule of law is being followed.
Here are some of the key considerations HR should be addressing (sharing the results with other departments as part of the FI’s overall pandemic response).
Please note that many of the responses will depend on the state and locality an FI operates in. Be sure to check with counsel and employment law when making assessments and decisions.
Many employees will be physically incapable of coming to work. They may be sick, taking care of infected family members, self-quarantined, caring for children due to school and daycare closures, or unable to commute due to public transit suspensions. The CDC and other sources suggest that companies need to be prepared to operate with just 40 percent of their workforce.
FI’s need to think about potential:
- Short-term employee staffing issues
- Long-term employee staffing issues
- Cross-training staff. It's never too late to start cross-training staff. It can even be done virtually.
Additionally, it's believed the virus is likely to come in waves, just like the Spanish Flu did in 1918.
Containing coronavirus in the workplace
By now we’ve all heard that it’s possible for someone to carry and infect others with COVID-19 even if they aren’t showing any symptoms. Your FI needs to think about what can be done to limit the potential for spreading the virus in the workplace. HR needs to think about:
- Social distancing
- Relying on drive-through over lobbies
- Making in-person meetings in the lobby by appointment only
- Cleaning measures & sanitary practices
- Supplies & protective equipment
- Can you restrict personal travel? Refuse to allow people to come in? (Encourage staff to follow best practices from the CDC. Currently the State Department strongly discourages international travel.)
- Send people home (You can typically send people home if they are sick.)
- Test people? Make people submit proof of health? (Check with your legal counsel on issues like medical screening for temperature. Also, it's unlikely you can screen customers.)
- Staggering work hours to limit large groups (split shifts)
- Do your sick leave policies encourage sick workers to come in?
- Pre-emptive quarantines (You may have to pay employees if you ask them to stay at home "on call" in case other staff get sick.)
- Preventing rumors with upfront communication (If you're not sharing information, your employees are speculating and sharing.)
- Is contact information up-to-date?
- Share human resources policies, workplace and leave flexibilities, and pay and benefits information.
- Will staff that can't come in or work remotely still be paid?
- Health confidentiality: If an employee is confirmed to have COVID-19 infection, inform employees of possible exposure but maintain the confidentiality of sick employee required by the Americans with Disabilities Act (ADA).
- Retaining a sense of community (Perhaps have virtual lunch or coffee gatherings for small groups of employees to chat.)
- You may want to consider channels for both public and anonymous questions.
- Can staff work from home? Do they know how?
- Do they have the proper equipment?
- Are they required to work from home?
- What about staff that doesn't have that option?
Make sure HR is coordinating teleworking policies with IT to ensure they are feasible and secure.
Most professional conferences have been canceled for the immediate future, but FIs are still able to arrange events like board meetings and retreats.
- Don't let a whole team travel to one place (What if they are quarantined and can't get home?)
- Personal travel (Can you limit where staff travels or encourage best practices?)
- Alternatives (How can board/customer/vendor meetings be held?)
As always, make sure your FI is consulting employment law when making risk assessments. Also, make sure HR consults with other departments when making risk determinations so they have all the information necessary to make an informed decision.
Risk management can’t work in a vacuum. We may be self-quarantining or sheltering in place, but when it comes to risk management, we all need to come together.