Teaching the Board How to Oversee and Monitor the Compliance Function

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1 Response

  1. Frank Numann says:

    Michael,
    I agree with much of what you are saying in this blog. It is important to educate the board of the programme’s performance and show them metrics. These most likely will trigger discussion and it is important that that takes place in the presence of the COO, who is the Subject Matter Expert. For instance, one issue that always comes up, is the question whether an increase in whistleblowing is a good sign (people feel confident to speak up and know they can feel safe when doing so) or bad (there is more incidents to going on than in the past). The COO can answer those questions with his/her deep knowledge.
    What I would be most careful with, is to apprise the Board of ongoing investigations, unless they are significant as a DoJ request for information. The Board must be aware of those from day one, of course. Other investigations need to be kept on a need to know basis (and the CEO doesn’t need to know until the COO is certain of the facts). Then we can discuss implications and benefit from the Board’s insights. But until the facts are known most cases are best managed very tightly as any indication that somebody is being investigated will leave that employee with a stigma. And that is unfair, as they are innocent unless proven to be guilty