The beauty of an effective ethics and compliance program is captured in the well-known phrase that it is worth much more than the sum of its parts. I am reminded of the Beatles refrain, “All Together Now,” (HERE) which is an apt reminder of the importance of operationalizing an ethics and compliance program.  Frankly, the life of an ethics and compliance program depends on the...

A chief compliance officer needs to be independent and have adequate authority within the organization.  But do not get confused by the concept of independence.  Compliance depends on collaborative relationships with other corporate functions. Most importantly, a compliance program’s success depends on its ability to embrace the company’s business.  To do so, the compliance staff has to learn and understand the company’s business inside and...