Crisis Management: Is Your Company Prepared?
Samuel Estreicher and James Philbin write: Recent disclosures that key employees have engaged in sexually abusive practices towards coworkers and job aspirants raises to the fore serious practical questions for corporate executives and in-house counsel. What should the company do to prepare for and manage crises?
December 01, 2017 at 02:35 PM
10 minute read
Recent disclosures that key employees have engaged in sexually abusive practices towards coworkers and job aspirants raises to the fore serious practical questions for corporate executives and in-house counsel. What should the company do to prepare for and manage crises?
A corporate crisis can come in many forms: In addition to a Harvey Weinstein-type scandal, a significant class action litigation has been filed, a government enforcement agency has begun an investigation or a prosecution that could jeopardize your standing as an approved federal contractor, criminal charges have been filed against the company or employee, something has gone wrong with a core company product or service, there has been a cyberattack targeting your company.
Any of these events can trigger undesirable publicity and other consequences that can adversely impact the brand of the company, company revenues and profits, customer relationships, shareholder interests, and employee interests. Indeed, some crises can threaten the viability of the company—see Enron, WorldCom, Arthur Andersen, Lehman Brothers, Bear Stearns, etc.
Many companies make significant mistakes in the early stages of a crisis, when emotions can run high, even at the top levels of an organization. Due to lack of preparation, we often see companies take premature and erroneous positions or make erroneous statements to the media. These initial missteps can often significantly inflame the crisis or, at the least, place the company in less advantageous position than it could have been in. Nevertheless, there are proactive steps and planning that companies should engage in to be prepared and react in the event a crisis emerges.
First, a crisis management team should be identified and assigned in the company. This may include for example, the CEO, CFO, COO, general counsel, compliance officer, communications director and HR Leader. Other team members can be added or dropped from the team depending of the facts of the matter.
Second, even if a crisis has yet to fully develop, the team should convene and begin the management strategy and perform a crisis risk analysis of the company. What are the material risks to business operations that could spell crisis? What are the compliance and governance risks of the business? What operations, products or service failures could create a crisis? Does your company operate in areas of the globe known for corruption? Consider a crisis event and your response.
Third, once a crisis had begun, the team should follow the following steps:
• Identify the stakeholders in the crisis: who may be adversely impacted? Directors, managers, employees, customers, shareholders/investors, vendors, business partners, affiliates and subsidiaries?
• Determine the need and scope of investigation to assess the facts of the crisis. Who will conduct the investigation? Internal legal department? External Lawyers and/or auditors? Subject matter experts? Other team members? While attorney client privilege may be important to protect the deliberation and strategic process, recognize that the facts (and reports summarizing data) will be discoverable. If the government is involved, recognize that the privilege may have to be waived.
• Does the company need to retain additional support or expertise? For example, are there security needs, public relations and/or lobbying needs, cybercrime expertise.
• Assess a communications strategy. Is the media involved or is it internal at this time? If a significant matter, assume it will eventually hit the media. Assign a person exclusively responsible for communications and interface with the media.
• Prepare a company position or holding statement. The company's credibility is critical, and truth is imperative; however, brevity is usually the best choice. If facts are unknown, do not state any. In addition, different but consistent holding statements/communications may be necessary considering the particular stakeholders and audience. In addition, holding statements may change over time as the matter proceeds.
• If media interviews are deemed necessary, the spokesperson must be properly prepared. Misstatements of fact or position can be very damaging to companies and alter the course of events.
• Continuously monitor the media coverage and consider need for additional responses or modifications to the holding statement. If multi-national in scope, the nature of media interaction may vary by region.
• Determine a team information exchange mechanism so team members can be contacted 24/7.
Fourth, complete a thorough investigation as soon as feasible and determine next steps or responses. It may be advisable that the response strategy be developed and decided by a subset of the crisis management team. Be cognizant of potential leaks and privilege issues during the response strategy process.
Fifth, once response strategy is complete, reconvene the crisis management team and assign response tasks to responsible parties with timetables for completion.
Sixth, the crisis response team should convene as often as necessary, constantly reassess the steps and strategy outlined above and respond as appropriate. Be prepared and open to strategic changes, sometimes drastic, as the matter and facts develops.
While some crisis may be unavoidable and even devastating to a company, proper crisis management preparation can avoid mistakes that can unduly exacerbate the situation. Remember, hope for the best and prepare for the worst!
Samuel Estreicher is the Dwight D. Opperman Professor of Law and Director of the Center for Labor and Employment Law, at NYU School of Law. James Philbin is the former U.S. general counsel of Maersk, the global transportation and logistics company. The two have recently formed the Philbin Law Group.
Recent disclosures that key employees have engaged in sexually abusive practices towards coworkers and job aspirants raises to the fore serious practical questions for corporate executives and in-house counsel. What should the company do to prepare for and manage crises?
A corporate crisis can come in many forms: In addition to a Harvey Weinstein-type scandal, a significant class action litigation has been filed, a government enforcement agency has begun an investigation or a prosecution that could jeopardize your standing as an approved federal contractor, criminal charges have been filed against the company or employee, something has gone wrong with a core company product or service, there has been a cyberattack targeting your company.
Any of these events can trigger undesirable publicity and other consequences that can adversely impact the brand of the company, company revenues and profits, customer relationships, shareholder interests, and employee interests. Indeed, some crises can threaten the viability of the company—see Enron, WorldCom, Arthur Andersen, Lehman Brothers, Bear Stearns, etc.
Many companies make significant mistakes in the early stages of a crisis, when emotions can run high, even at the top levels of an organization. Due to lack of preparation, we often see companies take premature and erroneous positions or make erroneous statements to the media. These initial missteps can often significantly inflame the crisis or, at the least, place the company in less advantageous position than it could have been in. Nevertheless, there are proactive steps and planning that companies should engage in to be prepared and react in the event a crisis emerges.
First, a crisis management team should be identified and assigned in the company. This may include for example, the CEO, CFO, COO, general counsel, compliance officer, communications director and HR Leader. Other team members can be added or dropped from the team depending of the facts of the matter.
Second, even if a crisis has yet to fully develop, the team should convene and begin the management strategy and perform a crisis risk analysis of the company. What are the material risks to business operations that could spell crisis? What are the compliance and governance risks of the business? What operations, products or service failures could create a crisis? Does your company operate in areas of the globe known for corruption? Consider a crisis event and your response.
Third, once a crisis had begun, the team should follow the following steps:
• Identify the stakeholders in the crisis: who may be adversely impacted? Directors, managers, employees, customers, shareholders/investors, vendors, business partners, affiliates and subsidiaries?
• Determine the need and scope of investigation to assess the facts of the crisis. Who will conduct the investigation? Internal legal department? External Lawyers and/or auditors? Subject matter experts? Other team members? While attorney client privilege may be important to protect the deliberation and strategic process, recognize that the facts (and reports summarizing data) will be discoverable. If the government is involved, recognize that the privilege may have to be waived.
• Does the company need to retain additional support or expertise? For example, are there security needs, public relations and/or lobbying needs, cybercrime expertise.
• Assess a communications strategy. Is the media involved or is it internal at this time? If a significant matter, assume it will eventually hit the media. Assign a person exclusively responsible for communications and interface with the media.
• Prepare a company position or holding statement. The company's credibility is critical, and truth is imperative; however, brevity is usually the best choice. If facts are unknown, do not state any. In addition, different but consistent holding statements/communications may be necessary considering the particular stakeholders and audience. In addition, holding statements may change over time as the matter proceeds.
• If media interviews are deemed necessary, the spokesperson must be properly prepared. Misstatements of fact or position can be very damaging to companies and alter the course of events.
• Continuously monitor the media coverage and consider need for additional responses or modifications to the holding statement. If multi-national in scope, the nature of media interaction may vary by region.
• Determine a team information exchange mechanism so team members can be contacted 24/7.
Fourth, complete a thorough investigation as soon as feasible and determine next steps or responses. It may be advisable that the response strategy be developed and decided by a subset of the crisis management team. Be cognizant of potential leaks and privilege issues during the response strategy process.
Fifth, once response strategy is complete, reconvene the crisis management team and assign response tasks to responsible parties with timetables for completion.
Sixth, the crisis response team should convene as often as necessary, constantly reassess the steps and strategy outlined above and respond as appropriate. Be prepared and open to strategic changes, sometimes drastic, as the matter and facts develops.
While some crisis may be unavoidable and even devastating to a company, proper crisis management preparation can avoid mistakes that can unduly exacerbate the situation. Remember, hope for the best and prepare for the worst!
Samuel Estreicher is the Dwight D. Opperman Professor of Law and Director of the Center for Labor and Employment Law, at NYU School of Law. James Philbin is the former U.S. general counsel of Maersk, the global transportation and logistics company. The two have recently formed the Philbin Law Group.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllPatent Trolls Come Under Increasing Fire in Federal Courts
Trade Fixtures in New York Eminent Domain Cases—What Qualifies and How Are They Valued?
10 minute readTrending Stories
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250