A CCO’s Vision Needs to Include “Line of Sight”
With the rise of chief compliance officers, come new terms and concepts. That is a good thing because it represents a maturation and standardization of the profession.
One of my favorite terms is “line of sight.” It is an interesting concept when you start to think of it. I suffer from literal interpretations – I am not a figurative person. So when I think of line of sight, I think of binoculars and the ability to see across great distances.
Applying this literal interpretation to the compliance profession reveals that there is even more to the concept. A CCO has to be able to see into all of the components of a company. That is what we mean by line of sight.
There are two big assumptions that go into the concept of line of sight – both of which are fundamental to the role of an effective CCO. A CCOs line of sight requires horizontal and vertical authority within an organization.
Horizontal authority describes the location of the CCO in the corporate organization. Vertical authority describes the CCO’s role across the organization, meaning across other components of the company. With horizontal and vertical authority, a CCO can exercise appropriate line of sight.
First, in order to see into each part of a company, the CCO needs to be at the highest part of a company. Another way of saying that is the CCO has to be a part of the C-Suite. The CCO has to be a senior executive in the management team.
We all know that elevating a CCO to the C-Suite is occurring more frequently but there is still more work that is needed in this area. Elevating a CCO to the C-Suite means that more than just a big office is required – CCOs have to be treated as one of the senior business team. They have to be included at senior management meetings and have a seat at the table when all significant business decisions are made.
This is a critical requirement for a CCO to have the status and ability in a company to raise ethics and compliance issues to the forefront of the company’s agenda.
CCOs also need more than just a seat in the C-Suite. CCOs also need authority to view into the other parts of the company. That requires a clear message – the CCO has the authority to enter into other parts of the company, recommend changes and work closely with other components.
With this authority, CCOs can exercise more than just management and oversight of compliance; they can monitor specific activities, and reach into the component with authority to collaborate and improve ethics and compliance performance.
Line of sight extends to authority and credibility. CCOs have to exercise their authority responsibly. CCOs depend on the performance of others who are willing to commit to the ethics and compliance function. A CCO never has enough staff to carry out compliance functions on his or her own – they need the support and buy-in of the business.