What separates a “good” ethics and compliance program from a “great” one? While there are a number of factors, in our experience, there are five that are key differentiators in the highest performing compliance programs.
- Tone at the top
- Corporate culture
- Compliance risk assessments
- Chief compliance officer
- Testing and monitoring
This paper focuses on the role of the chief compliance officer (CCO).
Enterprise ethics and compliance executives represent a young, but rapidly maturing profession—one that began to emerge in the late 1980s when several government initiatives and high level commissions began recommending that specific senior-level personnel should have responsibility for overseeing an organization's ethics and compliance program. These key business leaders are responsible not only for maintaining compliance, but also for safeguarding what is arguably an organization’s most valuable asset: its reputation.
CCOs now operate in a dynamic legal, regulatory, social, and economic environment that is often characterized by complex and sometimes conflicting rules and regulations. Regulatory expectations have risen not just in the United States, but globally, placing tremendous pressure on organizations, particularly those with international operations. Designing programs that help ensure compliance with all of these regulations and guidelines falls squarely on the shoulders of CCOs.
Yet this is only a part of their responsibilities. CCOs must also respond to a host of rapidly emerging new risks. For example, enforcement authorities have reached an unprecedented level of cross-border cooperation in an effort to control bribery and corruption. Money laundering is no longer solely an issue for the banking sector, but for organizations across all industries. Cyber risk and digital crime represent enormous threats to businesses everywhere, and organizations need to step up their efforts to ensure compliance with internal policies designed to address those threats. In addition, a more aggressive focus on transparency has brought many previously hidden conflicts of interest to light.
As a result of these developments, the CCO profession has begun to shift in ways that are subtle yet profound—an indication that organizations are acknowledging the significant role that CCOs play.
Download the PDF to learn how companies with world-class ethics and compliance programs make sure they have a world-class CCO leading the charge and protecting their reputation. You may also want to check out the other articles in our series (tone at the top, corporate culture, compliance risk assessments) or register for our Dbriefs webcast on June 25 to learn more about the chief ethics and compliance officer.