Introduction: The story behind the story

But when COVID-19 hit earlier this year, and one of Carnival’s ships became the first incubator for the virus outside of China, we knew we had a much bigger story on our hands.

So, we pivoted. Our account of Carnival’s compliance redemption morphed into “A Tale of Two Storms”: how a company that was in the midst of a compliance overhaul suddenly had to use its newly toned muscle to battle the biggest health crisis the world has seen in a century. The coronavirus might have grounded Carnival’s entire fleet, but it couldn’t halt the progress of its compliance revamp—not when it had a court-appointed monitor checking its progress at every turn.

The story begins with our visit to Carnival’s corporate Miami headquarters in February, a coincidentally timed inflection point—when the world’s largest cruise company went from dealing with one crisis (rebuilding its compliance program) to two (COVID-19’s spread). What we discovered was that the structural and cultural changes beginning to permeate throughout Carnival as part of the compliance transformation would inform its response to the pandemic.

We want to thank Carnival for its cooperation and transparency throughout the reporting and editing process of this case study. No company wants to talk about its mistakes, especially when they’re not that old. And especially when the organization is still working under a court-appointed monitor and in the process of rebuilding its ethics and compliance program. But Carnival did. Not only did the company take responsibility for its errors, it showed us what it was doing to correct them and explained the process behind it all. It’s that process, and those lessons learned, that we think will be invaluable for compliance practitioners who read this report.

In particular, we want to thank Carnival Chief Ethics and Compliance Officer Peter Anderson, who was incredibly generous with his time and provided invaluable insights into what it takes to rebuild an ethics and compliance program on a huge scale. He understood that by sharing his story with us, his fellow practitioners would be better for it.

Lastly, we owe a huge debt of gratitude to the author of this report, Compliance Week’s Aly McDevitt. Aly conducted dozens of interviews, read hundreds of pages of documents, and enthusiastically accepted the challenge of pivoting on the fly when she had to tear up her first draft after the coronavirus changed the world as we knew it.

We hope you learn from this story and that you share those lessons with colleagues in the collaborative spirit that makes the compliance community so unique.

Read on–Chapter 1: Amid compliance overhaul, COVID-19 hits Carnival hard