Embedding Compliance Personnel in Business Operations

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3 Responses

  1. Bill Wilson says:

    I always chuckle when I hear about a "new" model for something that some organizations have been doing for decades.  In 1986, I was attending the staff meetings of my business unit clients, as did many of my colleagues, an unheard of practice for the most part in many organizations.  It gave me insights I would never have gotten back in my office at headquarters, along with the possibility of early intervention when needed.  It also gave me visibility at a level of the organization that said "this function matters."  Embedding does not necessarily have to mean daily presence, though it can.  It simply means developing a close relationship with the client that puts you on their radar and availability that makes it painless to get your help.  

  2. This model is relatively new in pharma and has taken off in many large pharma companies.  When I started in international compliance ten years ago, it was unheard off to be former sales professional working in compliance.  I would suggest the embedded role its different than just spending time with clients. Today, in pharma, I'm no longer the exception.  For the last two years, I had the opportunity to serve as a senior-level compliance professional embedded on a BU leadership team.  I still reported to the CCO and we still had operational staff, but the value of working shoulder to shoulder with the business was invaluable for them and me. We saw ourselves as teammates with different responsibilites, but striving for the same objectives.    They saw me as member of their leadership team, contributing (not policing) to the development of business unit strategy and evaluating ideas before they were implemented.  I was also a sounding board and was received as a valued consultant to leadership.  Equipping leaders with enhanced risk accumen informed decision-making and made for far more impactful communications (form BU leaders, not me). Down the line, front line employees recognized me as a member of the leadership team, which gave credibility to compliance and demonstrated leadership's committment to ethics and compliance.  It was a very successful model highlighted in GSK's recent Corporate Integrity Agreement.

  3. John Buckley says:

    I agree with Bill Wilson.  I've seen these compliance management models evolve over 30 years as they are applied to each new compliance program that sprouts up.  The centralized support model often starts being too politically weak, and then the pendulum swings too far the other way to a centralized command model that imposes requirements on the business operations without much support, then the decentralized model tries to balance that out, then people eventually gravitate to a model that has some of both with an ocillation of political clout between central and decentralized.  The audit function should stay centralized, but a mix of decentralized compliance generalists and centralized niche experts usually is the end result.