CCOs and Resources: Put Your Money Where Your Mouth Is!
The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot commodities in the in the corporate governance world. It is an intoxicating time for compliance professionals.
In this environment, CCOs have to be wary. CEOs and other corporate leaders know how to talk the talk of compliance. But CEOs and other corporate leaders ignore how to walk the walk. In other words, they know how to persuade CCOs that they are committed to compliance and will support the compliance function. When it comes to delivering support in terms of resources and support, corporate boards, CEOs and senior leaders are falling short.
CCOs are being slowly strangled by a lack of resources. I am not just referring to headcount, but funding to purchase new technologies to leverage existing staff. CCOs are forced to request additional resources by pleading for support from the board, a CEO or a general counsel. These requests are often ignored or downplayed unless a company is under government investigation and threat of punishment.
In the absence of government investigation, CCOs face an uphill climb. As a result, CCOs are forced to make due with inadequate resources, and outmoded technologies. Many companies fail to understand the bottom-line benefits of a robust ethics and compliance program.
Companies that maintain an effective ethics and compliance program perform better than companies that fail to maintain such a compliance program. A company that fails to support its compliance program is cutting its own throat – employee morale will suffer, and productivity will decline. CCOs have to educate CEOs and the corporate board about the importance of supporting the compliance function with adequate resources – personnel and technology.
A model for CCO treatment is the internal audit function. In the face of Sarbanes-Oxley, audit committee chairs are more than willing to allocate resources when needed to ensure the accuracy of financial reports. Several internal auditors have told me that they are able to get the resources they need when they need them. No questions asked.
CCOs are entitled to the same treatment. For some reason, audit committees and senior executives treat CCO requests for additional resources in a different manner. CCOs have to push to change this situation by educating audit committee chairs and CEOs to support the compliance function.
CCOs have to challenge their leaders by stating a consistent message – compliance requires adequate resources and here is the list of resources needed to ensure an effective ethics and compliance program. Along with this clear message, the CCO has to educate the board, CEO and senior leaders on specific requirements for an effective ethics and compliance program.
In carrying out this mission, CCOs have to ignore “happy talk” of empty promises made by CEOs and senior executives. If a CCO wants to accomplish his/her objectives, a CCO has to be clear about program requirements.
I hear continuing complaints from compliance professionals about lack of resources, and frustration over CEOs and senior leaders who ignore or reject requests for more resources. CCOs have to continue pushing this issue, educating boards, CEOs and senior executives on the importance of achieving an “effective” ethics and compliance program.