Almost all of the world has condemned the Russian invasion of the Ukraine and I will add my small voice to that condemnation. In trying to choose what to write, I did not want to emphasize or better the geopolitical commentary, so I decided to focus on how this invasion and its attendant fallout might impact compliance professionals and programs. At this point Russia has limited its attacks to Ukraine but my fear as more EU, other Western allies and the US respond with arms and technical support to the Ukraine government and army, we might see Russia unleash its cyber warfare specialists on those who are supporting Ukraine with material and other support. This week I am writing about some of the issues a Chief Compliance Officer (CCO) needs to think about now. Today, I consider employees in Ukraine.
Many of the issues related to Ukraine are similar to those we looked at when it came to Russia. Obviously Supply Chains which are centered in or go through Ukraine will be significantly impacted. However, as you move west from Ukraine there may soon be greater disruptions into Poland and other eastern European countries as the war intensifies and continues unabated. While many US, UK and EU companies have employees in Russia, they are not now under attack. What can or should you do for your employees that are domiciled in Ukraine?
 Contact and Other Information
Some of the things I learned in weather related emergencies on the Texas Gulf Coast are applicable to the current situation and some are more unique to a war-torn environment. The first thing you need to do is have a full list of all your employees, together with primary and secondary contact information. According to Remote.com this is because “it is common for means of communication to become unreliable. Your team members in Ukraine may lose access to the internet for a few hours or days at a time. If that happens, your people will need to know how to reach you. Provide a direct phone number so you do not lose contact should a member of your team lose internet access.”
Beyond this basic contact information, you should also confirm all employee information. Accurate records can be extremely important in recovery after conflict or for relocation purposes. Ascertain your organization has “the most up-to-date information for all of your team members  in Ukraine, including addresses, bank account information, legal status, citizenship, and anything else that may be important.” The next step would be to “scan and store significant documents to protect against potential loss or damage. Your HR or people team should handle this duty to preserve any documents sent while maintaining the privacy and confidentiality of your” employees’ sensitive personal information.
Financial Support
Banking services will become untenable at some point. Your organization may want to provide advance funding to Ukrainian employees ahead of normal payroll cycles to assist in recovery or relocation. Even if banks, ATMs or cash points remain open they still have to be physically replenished with hard currency. Of course, internet access will become unreliable during conflict. Your employees may not be able to access their funds, or they may need to receive funds quickly and “delivered directly to accounts other than their usual bank accounts. Please keep in mind that paying for services in deemed unsecured cryptocurrencies is currently prohibited in Ukraine. As always, delivering funds outside traditional bank accounts can carry additional risks, so be careful to ensure the funds actually reach the person you are trying to help.”
There can be other forms of financial support, including giving paid time off until the situation has stabilized, or by paying for relocation costs such as hotel fees and travel expenses. Companies might also look at providing supplies to their employees including the delivery of groceries, medicine and other much needed products directly to employees. Coordinate with your employees about this option and offer to pay for any supplies they might need at this time. Lano notes, “A precondition for any further assistance is that you remain in constant contact with your employees. Several daily check-ins are advisable in exceptional situations in order to be informed first-hand about what is actually happening on site and to be able to initiate immediate actions if necessary.”
Relocation
Many of your Ukrainian employees will choose to stay in their country, but others will want to leave, either during the height of the conflict or in the event of a Russian occupation. There are already rumors of Russian kill lists. Make sure you talk to your employees about this possibility and support them in finding a new temporary home. Providing relocation assistance for your employees and their families may be one of the most critical pieces of support you can offer. This could include such services as “emergency immigration, special work permits, and emergency visas may all be options for team members wishing to leave the country.” Drawing from my experiences during the evacuation of New Orleans after Hurricane Katrina, companies who have offices in different locations might be able to source support within a local team or mobilize colleagues from different offices to connect and provide a temporary shelter.
Connections, Connections, Connections
Do not assume people want to be left alone. According to DistantJob, “The first thing you can do to help your employees affected by the Ukrainian-Russian conflict is asked them how they are doing. Make it clear that the most important thing right now is for them to be safe, so clear their schedule, and let them know they are in no obligation to attend any meetings or meet any deadlines.”
However, some people may prefer to remain in contact as usual. Allow your employees to decide what makes them most comfortable and accommodate those choices to the best of your ability. Along similar lines, obtaining reliable information inside a war zone can be problematic at best. Already many of Ukraine’s government websites were hit by cyberattacks, making it even more difficult for Ukrainians to receive communications through official channels. From outside the country, you may be able to relay information your employees will be unable to discover on their own. Watch for news that may be helpful to your employees, especially if they lose internet access. Share information you come across that may be related to providing food, water, shelter, or transportation in the areas where your employees reside.
But most importantly connect, connect and then connect more.
Next up, a look at Supply Chain issues.