Navigating the multitude of regulations and Ministerial pronouncements in South Africa due to the emergency situation of Covid-19 has proven challenging as to what is and what isn’t allowed. Fortunately for the financial services industry, financial services including banks, insurers, pension funds, savings and investment has been broadly classified as an “essential service” under Annexure D of the Disaster Management Act, 2002 from the beginning of the crisis and allowed to operate under the most stringent of lockdown conditions. The South African government has recognised the importance of these institutions and the impact of impeding their operations would have on the economy.
Although a large part of the financial services industry is allowed to work remotely, there is a portion of the business such as the trading desk or those that perform pricing that require access to more sophisticated computers and software that is only available at the office. And therefore, most of the financial services industry has remained open with a small portion of essential workers physically working in the office. But with a third of the workforce allowed to return this week, it is not clear whether the financial services industry is adequately prepared for this. Although the financial services industry is required to have business continuity and disaster plans (BCP), the previous ones certainly did not cater for a COVID-19 situation and social isolation. Instead, most BCPs provide for a secondary off-site location for the workforce but the workforce would still be working together with no remote working or isolation measures.
The advice therefore for all financial services institutions is to first focus on complying with all of the current regulations in respect of COVID-19. This includes providing adequate space for employees to work, two cloth masks and regular wiping down and sterilising of surfaces. But beyond the basic compliance with operating in this emergency situation, it is recommended that the financial services industry make long-term contingency plans for the “new normal” and to not view this situation as temporary and up-date their BCP urgently. It is also likely that it would become a requirement for BCP plans to cater for these types of pandemics going forward.
Suggestions for some of the measures that the financial services industry could implement:
· Ensure all of the required workforce has laptops and can work remotely with data.
· Consider private transport options for workers who are required to be physically present such as cleaners.
· Extend the current BCP to include scenarios if an essential employee physically working in the office does get infected with COVID-19 and the office forced to close down including the trading desk etc. This may include measures such as setting up specialised computers in individuals’ private residences.
· Provide extensive back-ups and options for key person decisions allowing for all current key persons to get infected.
· Ensure that the business’s IT and remote working situation is secure and reviewing their IT security protocols for remote access and cloud sharing.