No Result
View All Result
SUBSCRIBE | NO FEES, NO PAYWALLS
MANAGE MY SUBSCRIPTION
NEWSLETTER
Corporate Compliance Insights
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
No Result
View All Result
Corporate Compliance Insights
Home Governance

A Seat at the Table for the Compliance Officer

by Donna Boehme
March 11, 2014
in Governance
A Seat at the Table for the Compliance Officer

“If you are not at the table, you are likely on the menu.”
-Anonymous

In a recent blog, former federal prosecutor Michael Volkov, a good friend to the compliance and ethics profession asked: “Where is your CCO’s Office? An Important Question!”

And one that raises the larger issue of a “seat at the table” – a key feature of any effective chief compliance officer (CCO) role.

A company can have a compliance program with all the bells and whistles on paper. Chief compliance officer? Check. Status reports to the audit committee? Check.  Code of conduct? Check. Training (onsite and e-learning?) Check. Check.  But hold on.  Anyone can do a “check the box” inventory. As Volkov suggests, once you get past the “paper program” and begin to ask more probing questions, that’s when the real picture begins to emerge.

A chief compliance officer can have the title and the business card, but do they have a seat at the table where the organization’s important business is discussed and decided?  For instance, do the heads of business, audit, legal and HR participate in the firm’s quarterly business review while the CCO stands outside, nose pressed up against the windowpane?  If so, that sends a powerful message to management (just not a good one), without a single word being spoken.

Here’s one of my little tests: if a powerful business leader were to call the CCO on the carpet and demand that a compliance investigation be “closed” or to know the name of an employee who raised a confidential concern, what happens?  If that isn’t an automatic trigger event requiring nondiscretionary escalation to the governing body, then “Houston, we have a problem!” In that case, not only do you have a culture problem, you probably don’t even have a credible compliance program.

Which brings us back to the CCO’s office location.  Seems petty, right?  Why should the office location even matter? Why are these pesky CCOs so power hungry?  On the contrary, my observation from more than 20 years in the field is that CCOs are probably the least power hungry managers in the room. But they want to do their jobs well and deliver on the promises made by the company when it rolled out its code, confidential helpline and other elements of the compliance program.  And to do that, CCOs need all the tangible and intangible indicia of empowerment they can get.

These include an appropriate title, reporting line, written mandate, line of sight, resources, a seat at the table, nondiscretionary escalation to the Board of significant matters and yes… an office that says to the organization: “compliance matters.”  Because unlike other, more established functions of the organization such as legal, audit and HR, the compliance function is fighting for every mandate and crumb of credibility that it can grab hold of so that powerful leaders view them as a member of senior management and not as mere window dressing.

It’s also important because employees want to know if the CCO is independent and able to protect them against retaliation.  They know the difference between talk and walk – and it shows in all the small and not-so-small ways that employees easily recognize.  Where the company falls on the  spectrum of walk and talk makes all the difference between an engaged, informed and transparent workplace where people feel safe in raising their hands, and a Twitter headline (#Scandal) waiting to be written.

Here are some other questions for proactive Boards and CEOs:

  • When important management meetings occur on strategy, risk or reviews of business performance, is the CCO at the table?
  • Is the CCO’s input sought as part of management’s compensation, evaluation and promotion process?
  • If your organization has, as many companies do, an annual or periodic summit of its top managers, is the CCO not only invited as a senior leader, but also prominently on the agenda as a key speaker?

A seat at the table: it’s a critical feature of any successful CCO position, and by extension, any effective compliance program.   Over the last five years, the CCO has made significant strides in independent reporting line and direct, unfiltered access to the Board – but without a seat at the table, the impact of the first two may be completely eviscerated.  The CCO must be present, connected and impactful.

And, as Volkov observes, the CCO’s office is pretty important, too.


Previous Post

A Possible Cure for the Hardening of Corporate Arteries

Next Post

The Importance of a Risk Assessment

Donna Boehme

Donna Boehme

  Donna Boehme is an internationally recognized authority in the field of compliance and ethics, designing and managing compliance and ethics solutions for a wide spectrum of organizations. Founder and Principal of Compliance Strategists, a N.J.-based consulting firm, Boehme is the former chief compliance and ethics officer for two leading multinationals. She is a frequent speaker to business and professional groups, including as keynote speaker to Compliance Week Europe (Brussels), Ethics Practitioners Association of Canada (Ottawa), Society of Corporate Compliance and Ethics, International Financial Executives Leadership Forum (Montreal) and Network for Good Business Ethics and Non-Financial Reporting (Copenhagen).She has been invited to speak twice on international corporate compliance and ethics topics at the U.K. House of Lords. Boehme is also co-chair and co-founder of the RAND Compliance and Ethics Symposia series, an important vehicle of thought leadership for the profession.

Related Posts

launch visual lease esg steward

Visual Lease Launches ESG Tool for Asset Portfolios

by Corporate Compliance Insights
March 31, 2023

Lease software provider Visual Lease announced it has launched a new product, VL ESG Steward,  designed to help organizations track...

PW FCPA Enforcement and Anticorruption 2022 Review_f

FCPA Enforcement & Anti-Corruption Developments

by Corporate Compliance Insights
March 30, 2023

The year that was in FCPA & anti-corruption efforts 2022: A Year in Review FCPA Enforcement & Anti-Corruption Developments What’s...

JTC ESG and Impact Investing_f

The Evolution of ESG & Impact Investing: Are You Ready?

by Corporate Compliance Insights
March 30, 2023

Making money *and* doing the right thing Survey Report The Evolution of ESG & Impact Investing: Are You Ready? What’s...

Regology 2023 State of Regulatory Compliance_f

2023 State of Regulatory Compliance

by Corporate Compliance Insights
March 30, 2023

Understanding the impact of regulatory challenges Survey Report 2023 State of Regulatory Compliance What’s in this report from Regology:As the...

Next Post
The Importance of a Risk Assessment

The Importance of a Risk Assessment

Compliance Job Interview Q&A

Jump to a Topic

AML Anti-Bribery Anti-Corruption Artificial Intelligence (AI) Automation Banking Board of Directors Board Risk Oversight Business Continuity Planning California Consumer Privacy Act (CCPA) Code of Conduct Communications Management Corporate Culture COVID-19 Cryptocurrency Culture of Ethics Cybercrime Cyber Risk Data Analytics Data Breach Data Governance DOJ Download Due Diligence Enterprise Risk Management (ERM) ESG FCPA Enforcement Actions Financial Crime Financial Crimes Enforcement Network (FinCEN) GDPR HIPAA Know Your Customer (KYC) Machine Learning Monitoring RegTech Reputation Risk Risk Assessment SEC Social Media Risk Supply Chain Technology Third Party Risk Management Tone at the Top Training Whistleblowing
No Result
View All Result

Privacy Policy

Founded in 2010, CCI is the web’s premier global independent news source for compliance, ethics, risk and information security. 

Got a news tip? Get in touch. Want a weekly round-up in your inbox? Sign up for free. No subscription fees, no paywalls. 

Follow Us

Browse Topics:

  • CCI Press
  • Compliance
  • Compliance Podcasts
  • Cybersecurity
  • Data Privacy
  • eBooks Published by CCI
  • Ethics
  • FCPA
  • Featured
  • Financial Services
  • Fraud
  • Governance
  • GRC Vendor News
  • HR Compliance
  • Internal Audit
  • Leadership and Career
  • On Demand Webinars
  • Opinion
  • Resource Library
  • Risk
  • Uncategorized
  • Videos
  • Webinars
  • Well-Being
  • Whitepapers

© 2022 Corporate Compliance Insights

No Result
View All Result
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe

© 2022 Corporate Compliance Insights

Welcome to CCI. This site uses cookies. Please click OK to accept. Privacy Policy
Cookie settingsACCEPT
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT