Structuring the Chief Ethics and Compliance Officer and Compliance Function for Success (from The SCCE Complete Compliance and Ethics Manual)

By Donna Boehme

Why This is Important

In an ideal world, a company that is establishing a new chief compliance and ethics officer position (CECO) would dedicate considerable time and effort to high-level strategic thinking, contemplating the mandate for the function, the proper positioning for the officer, the competencies and experience necessary for the new position, and the resources required to do the job. After all, as your mother always told you, anything worth doing is worth doing well. But all too frequently, as reflected in the steady parade of companies with failed compliance programs in the headlines, the CECO position is created in haste and repented in leisure—sometimes under the watchful eye of a prosecutor or corporate monitor. In today’s perilous regulatory environment where carefully nurtured corporate reputations can be destroyed on the strength of a single individual act, revealed at the speed of a single Tweet or blog post, the CECO is the company’s first line of defense (after the business itself). Compliance-savvy boards and senior management could make no better use of their scarce time than ensuring that their CECO and compliance function are structured for success, in a manner that is fit-for-purpose for their organization’s size, scope, risk profile, structure and culture. To facilitate this important endeavor, this chapter sets out a principles-based analysis based on five key criteria that are relevant to any CECO in any company: empowerment, independence, seat-at-the-table, line of sight and adequate resources—so that companies can structure their CECOs and compliance functions strategically for success, before prosecutors, regulators, investors or other stakeholders compel them to do so.

. . .

(Read the full report)

(Read – Appendix 3k – Twenty Questions That Boards Of Directors Should Ask About Compliance And Ethics)

3 thoughts on “Structuring the Chief Ethics and Compliance Officer and Compliance Function for Success (from The SCCE Complete Compliance and Ethics Manual)

Leave a Reply