Mike Scher – The FCPA Blog – November 9, 2015
In the prior post, I mentioned the role of boards of directors in adopting the company’s code of ethics. In this post, I’ll talk about the critical reasons for board-backed codes of ethics.
As we’ve said, under Compliance 2.0, compliance officers aren’t part of the legal department, and the chief compliance officer isn’t working for the general counsel.
A question, then, is how compliance officers, in their new role without legal department authority, can stop lawful but awful projects? Lawyers have the force of law behind then, and the potential of prosecutions against the company. What will back up the authority of the compliance officer?
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