The role of the BPO provider is no longer just delivering services. They need to bear some responsibility as watchdogs.
This is more of a blog than a column. As I am writing this, I am currently attending the CRO Summit in Washington, DC this past April. I am listening to a panel of BPO providers discussing managing compliance in the era of corporate responsibility.
The CRO Summit series (www.thecro.com) is part of an offering by CRO Magazine and the CRO Association. The acronym stands for Chief Responsibility Officer. The mission of this group is the professionalization of an area that subsumes corporate responsibility, sustainability, and governance risk and compliance. There are important crossovers for HRO BPO. For example, talent management is a major issue in corporate responsibility and a special interest group of the CRO Association. Employment branding is heavily related to a company’s responsibility profile. Corporate responsibility is going to be a topic of growing importance to HRO providers and senior HR leadership.
David Goode of Tata Consultancy, Charles Bartel of Manpower, and Suranjan Pramanik of Infosys BPO all discussed the various ways their companies addressed the rigors of BPO compliance management in the new world order. Glenn Davidson of EquaTerra, in moderating the panel, went right at issues such as the Satyam accounting scandal and the need to meet the responsibility requirements of the provider agenda and the client agenda.
It occurred to me that the world has changed a great deal. Providers need to live in a new era of common sense. Where does the role of provider end and whistle blower begin? What is technically compliant and morally sound?
Responsibility in the HR profession is hemmed in on all sides by local and national laws, EEO and OFCCP guidelines, and professional codes of conduct. It would seem in the current financial crisis, however, that the phrase “plausible deniability” gets too much use, as in “We did not know or did not realize what we did” or “it was not technically against the rules so we were in compliance.” HRO and other BPO providers were not at fault for the debacle, but all executives should learn from the weaknesses of these responses.
role of business executives—whether overseeing financial or HR—is not only about measurement and recordkeeping. It is also managing and discerning dishonesty in the business. Common sense is a cornerstone of responsibility. Most times people are doing something they know may be wrong but try to rationalize it or, worse, consciously do it anyway. The coming storm of “reregulation” as some are calling it is the result of the bad acts of the few leading to the punishment of the many.
Should a BPO provider be considered an accomplice if it manages aspects of compliance reporting or be culpable if it does not inform the proper authorities? In the case of law breaking, the answer is simple: Yes. If a provider sees law breaking, it needs to inform the company’s chief compliance officer or the chair of the audit committee. In the case of irresponsible actions that are not so clearly illegal, the provider needs to discuss with the appropriate members of the C-suite the behaviors that concern them.
Merely providing service and maintaining records are no longer enough. We live in a new era of responsibility, and your entire internal department and external resources now have to consider not only what is compliant but what is sensible, what is responsible, what is sustainable, and what is in the best long-term interest of shareholders, employees, and customers.
Elliot H. Clark