Managing Investigations is a World of Transparency

By Stephen O'Keefe - President, Bottom Line Matters

There are 2 things we can be sure of in today’s world of Loss Prevention and Investigations. Firstly when an incident takes place, there is no shortage of CCTV footage or cell phone videographers to draw from. Secondly, when an arrest is made, there is no shortage of folks who claim they were not surprised and knew something.

So why didn’t they say something? Well, they may have. But they were heard above the noise.

Many retailers have adopted the practice of “hands off”, or “no arrest" for fear of having that footage appear on the front page of the most sourced news or social media channels, as well as safety reasons.

Then there are the regulators; those tasked with policing our operating practices. In essence they are there for the right reasons, to make sure we do what we are supposed to do. How they do this differs from one agency to another, and in some cases when the agency is self-funded and relies on the fines they impose, their ability and motivation to catch us doing something wrong is far beyond our wildest expectation.

So how do we make sense of this new world of investigating in a transparent world? A world that is watching our every move.

I recently tried to help a client navigate through all of this, and thought I would provide an outline of the methodology I used to get them to where they need to be.

The 3 step process to build a management system

Quite simply the three step process is to; (1) conduct a risk assessment, (2) conduct a gap analyst, and (3) implement a process improvement plan.

The risk assessment covers the regulatory requirements of running the business, as well as the operational components to delivering results based on the strategy of the business. I use a heat map to weigh out the most important items, in terms of the impact and probability that they will be a hurdle or have a detrimental effect on the results.

Once the first step is complete the gap analysis measures those requirements against the actual operating practices used by your staff. This is where you have an opportunity to save yourself from major surprises. When you find the gap, move on to the next phase.

The process improvement phase is about developing a change management strategy to make sure you close the gap. Et voila! - your standard operating practice!

Policy

Once we completed our three step phase for our client it was important to draw a line in the sand. Policies, operating manuals, and standards are all about doing things the way the business wants them done. Shortcuts used can also be considered policy if you don’t react, which takes visibility to know they are ongoing.

Teaching and training

A CEO for a company I worked for summed it up this way; an employee will execute standard operating practice well if they (a) know how to, (b) are able to (c) have the tools to, and most importantly (d) want to, succeed.

This is the time to invest in your ambassadors who at times are tasked with doing what you expect even when you are not around. Why would you not place a high emphasis on teaching and training.

Oversight begins at home

No matter how well you set your standard, and give employees the skills to do a good job, there are always exceptions to SOP. Retailers open their doors to the public and have to expect the unexpected. This is a fluid and dynamic business and any good old school retailer will tell you - “inspect what you expect”!

As we drew closer to the end of our review, it was obvious that audits, and reviews, store visits if your will, were critical to making sure exceptions were flagged before a third party did it for them.

Give them the tools to report

Now for the essence of this article. Times are tough, and resources at times strained, so you can’t be everywhere at the same time.

If it is true that any time an incident took place somebody makes the statement that they knew, then it stands to reason that this is one of the greatest resources you have. How to tap into this grass roots knowledge is another story.

Publicly traded companies have a whistle blower type of requirement in most countries. And if you have followed the headlines in the news in 2019, you will understand this is not only a nice to have - it is a need to have. Be careful what you ask for because you have an absolute obligation to listen to, react to, and respond to allegations made related to ethics, integrity, regulatory violations, human right violations, health and safety issues, and crime in general.

Be transparent, open and objective

Whether you implement an internal hotline, or use a third party, make sure you offer an inviting, and objective process on how you solicit with this information. Make it safe for an employee by allowing them to report allegations anonymously if they feel they need to.

Triage the incoming reports

I have always advocated for cross functional repose to business problems and issues. We all know what happens when we treat an issue in a soloed business. Things get swept under the rug for fear from those who are defensive and territorial.

Get HR, Finance, Operations, Audit, Legal and Loss Prevention in a room and challenge them with a hypothetical scenario and I can guarantee you will get very different responses. This is a good thing, it ensures all bases are covered.

Improve the business

Make a plan, and resolve the issue. Then plan again to close the gap, and see step three of my 3 step process on process improvement to start the cycle over.


Stephen O’Keefe is a retail consultant working directly with retailers, vendors and management consulting firms in the areas of loss prevention, risk management, process improvement and general operations under the brand Bottom Line Matters. He has thee decades of experience working directly in retail for some of North America's top brands such as Sears, Hudson’s Bay, and most recently Walmart as their Vice President of Loss Prevention and Risk Management for Canada with seconded duties in the Mergers and Acquisitions division for the corporation’s global operations.

His client WhistleBlower Security provide a platform for third party anonymous reporting, tracking, and advisory services for ethics, integrity and criminal activity concerns for clients in dozens of countries globally.

Bottom Line Matters and WhistleBlower Security have partnered to create a webinar covering the critical aspects related to oversight, transparency and objectivity of the whistleblower value.

Click here to register for their free webinar on Sept 26th.