Defining Compliance 2.0: Key Compliance Partners (Part 5 of 5)

Michael Volkov – Corruption, Crime & Compliance – December 4, 2015

I always use the “Streetcar Named Desire” line to describe the challenges a  Chief Compliance Officer faces – CCOs depend on the kindness of strangers.  It is a little bit of an exaggeration but bear with me. CCOs are not superheroes and cannot by themselves ensure an effective ethics and compliance program.

An effective compliance program depends on a positive working relationship among the key compliance functions in a company. CCOs have to work closely with the General Counsel, the Internal Auditor, Human Resources, CFO and Comptroller, Information Technology, Security, Procurement, Senior Leadership Team, and of course, the CEO.

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Defining Compliance 2.0: Senior Leadership (Part 4 of 5)

Michael Volkov – Corruption, Crime & Compliance – December 3, 2015

Individual commitment to a group effort – that is what makes a team work, a company work, a society work, a civilization work.~ Vince Lombardi

Like so many areas in life, a successful ethics and compliance program depends on teamwork. My last two postings, Parts 4 and 5, will highlight these essential partners – senior leadership and key compliance functions.

In a company culture, teamwork is vital. There is always room for individual accomplishments and rewards but when it comes to ethics and compliance, teamwork is an essential piece. A compliance program depends on joint acceptance, activity and commitment – most importantly by business leaders in the company.

I have seen too many companies that focus primarily on the performance of the board, the CEO and the CCO, and ignore the valuable contributions that senior executives can make to an ethics and compliance program.

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Defining Compliance 2.0: The CCO (Part 3 of 5)

Michael Volkov – Corruption, Crime & Compliance – December 2, 2015

These are heady days for Chief Compliance Officers. Over the last 20 years, the CCO has moved from the backwater of corporate offices to the front and center of the power structure.

We now have debates over the independence of the CCO from the legal function, the reporting obligations and the relationship between the CCO and the board.

There is no question that CCOs have gained in the corporate structure. But CCOs have to be careful on two important fronts – they cannot overpromise on results, and they have to deliver in tangible ways on the business side of the equation. If CCOs mess up big time, or if they fail to communicate realistic expectations, CCOs will quickly suffer the budget ax and retribution from the board and CEOs in response to any major legal violation or reputational issue.

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