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What’s in a Title? – CCOs versus CECOs

title2As the compliance profession continues to ascend, I hate to divert attention to what may appear to be a trivial issue.   We all know that too much time is spent on issues such as size of offices specific titles given to various positions, and other topics that are not focused on important organizational purposes and tasks.

This issue, however, may carry symbolic importance.  The location of an office is not a trivial issue when it demonstrates the importance an organization places on the compliance function.  A seemingly trivial issue can become very important when considered in context.

The same can be said for corporate titles.  A compliance program is not just a compliance program – it should be an ethics and compliance program.  Everyone understands or should understand that an ethics and compliance program is far more than a program designed to detect and prevent code or legal violations.

Similarly, the Chief Compliance Officer is not just dedicated to compliance with the code and legal requirements.  Instead, the person’s title should be Chief Ethics and Compliance Officer.  There is a big difference between a CCO and a CECO.

I may be struggling with a small issue but I would argue that this is no small issue – the head of an ethics and compliance program cannot be described by the short-hand of a CCO.  I know I am parsing words and symbols here but it is important to a corporate culture to reinforce the importance of corporate ethics, a value which transcends compliance, and which complements and enhances the overall corporate compliance program.

When reviewing a corporate compliance program, it is one of the first issues I spot.  The title reflects the standing and the overall stature of the ethics and compliance program.title3

CECOs are moving into the C-Suite and gaining authority and resources.  As they do so, they deserve internal and external recognition through important symbols — location of an office, title and compensation.  They either are C-Suite executives or they are not; and they should be treated as the same.

A corporate title is no laughing matter.   It is not a trivial issue to an executive who has overall responsibility for every part of the corporate operation to make sure that the company has a proper ethical culture and is in compliance with the corporate code and legal requirements.

Companies cannot speak out of both sides of their mouths or they will face the inevitable consequence of a misguided corporate culture and compliance program.

titleThe easiest and most effective way to communicate the importance of the ethics and compliance function is to adorn the executive responsible for such a program with the appropriate title.  For those who have the title already, you are one step ahead in a long race to implementing an ethical culture that is designed to promote compliance with corporate code and the law.

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