A Claim Scenario:
Financial Services Company, India
Situation:
Management at the Indian call center of a European bank are notified by local employees that they are going to be targeted by protestors who believe the bank’s operations will introduce COVID-19 to the community. The protestors fear that senior managers from Europe have been exposed to the virus and will spread it among the 200 call center employees who are all locals. The intent of the protestors is to shut down the call center. This at a time when the bank is experiencing extremely high call volumes because many Europeans customers are unable to go to their local branch. The bank’s country manager triggers the SIR policy under threat of civil commotion.
Response:
Control Risks immediately appoints a case manager based in their Delhi office. Security consultants are deployed and provide recommendations on site security and employee transport routes. In addition to liaising with local law enforcement it is also agreed that additional guards are required for the periods that protests are due to take place and temporary security fencing is installed to protect the safe route to the site. One of the client’s security team members, normally based in Europe, deploys to provide additional reassurance and to be a local point of contact for the business.
Under the direction of the case manager, Control Risks’ cyber researchers and analysts conduct research for any organization or individual that is driving this community action, as well as identify key local leaders who can be leveraged for community outreach.
Outcome:
The client is fully prepared for the protests. The bank’s facility is not directly affected because of the security measures implemented. The impact of the event is minimized and the client is able to continue operations while they engage with community leaders.
The SIR policy indemnifies the client for the cost of the additional security related expenses incurred.
A Claim Scenario:
Technology Company, Poland
Situation:
Numerous whistle-blowers within a leading technology company make allegations against the head of sales of their Polish subsidiary. The allegations accuse him of taking payments from at least six customers in exchange for favorable pricing. Meanwhile the client is in the midst of responding to a global crisis and does not have the bandwidth or resources needed to investigate these claims. The General Counsel triggers the SIR policy under the allegation of internal bribery and corruption.
Response:
Control Risks’ Eastern European based team works, under privilege, with the client’s external legal advisors. They conduct targeted research and on-the-ground enquiries of the specific customers named in the allegations. Control Risks finds that the companies were owned by the wife, mother-in-law and childhood friend of the head of sales. It becomes clear that the employee is selling the client’s technology to these six companies at below market rates. Control Risks’ research also linked that the head of sales is active in supporting the government bids of these companies. For the client, this transforms a conflict of interest investigation into a potential FCPA matter since their products are being used on local government-run projects.
Outcome:
The evidence gathered is used to confront and dismiss the employee. The understanding of the scheme enables the client to implement measures to mitigate the likelihood of repeat incidents. These actions halt further loss of millions of dollars of sales revenue.
The client self-reports the corruption to the DoJ using the findings of Control Risks’ investigation. The swift and comprehensive response to the corruption allegations by the client was favorably viewed by regulators and reduces the multi-million dollar FCPA fine.
Had it not been for the much needed immediate and additional capacity provided by the SIR policy the investigation would have been delayed for an undetermined amount of time resulting in higher losses from the fraud being committed and a greater FCPA penalty.
A Claim Scenario:
Capital City Airport, Latin America
Situation:
Protesters entered a capital city airport in Latin America. Within hours law enforcement deployed tear gas against the protesters inside the airport. Chaos ensues. All flights are cancelled, the airport is on lock-down and our SIR policyholder, an international airline, has 30 staff and about 100 passengers inside the terminal. The SIR policy is triggered under civil commotion.
Response:
Immediate telephonic support and advice, including input from regional experts, is provided by Control Risks. Two security teams are deployed to the airport within 3 hours to arrange the secure transportation of staff and passengers away from the airport.
Control Risks’ analysts continued to monitor the situation over the next few days providing analysis and advice on whether to go ahead with the next day’s relief flight and future flights.
Outcome:
All airline staff and passengers safely left the airport. Due to the monitoring of the on-the-ground situation and the advice provided by Control Risks our policyholder was the only US airline which continued its regularly scheduled flights into this Latin American capital city. As a result there was minimal impact to the airline’s operations, revenue and reputation.
* Event Footage: https://www.youtube.com/watch?v=ZDhhN0GaAMs