Donna Boehme – Compliance & Ethics Blog – January 20, 2016
Now that FCPA Expert Tom Fox has set out Compliance 2.0 as one of his key 2016 trends, here are my top five recommended 2016 resolutions for modern Compliance 2.0 CCOs:
1. Prioritize Everything.
Maximize your effectiveness by prioritizing every activity and decision. I’ve never met a CCO with an overflow of time on their hands, and therefore I always counsel CCOs to have a plan and to prioritize, prioritize, prioritize. Because, as the great Stephen Covey powerfully wrote: “Begin with the END in mind!” No better mantra for CCOs has ever been written or imagined!
2. Live by your Mandate.
Clarify your mandate and role, once and for all. The first step to a robust compliance program that works is a strong CCO with a clear, unambiguous mandate. This is usually the fatal flaw in, and missing element from, Compliance 1.0 programs. The engine that drives a modern effective compliance program is a clear, independent Compliance mandate that is embraced by everyone, from the Board to the mail room.
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