One of the many great experiences I have been fortunate to have in my career is to meet some impressive leaders – at the Department of Justice, on Capitol Hill, and in corporations. To focus on the latter, I have met some amazing CEOs, Chief Compliance Officers, and other senior executives. To be candid, I have also met some not-so-great CEOs and senior executives. To...
Corporate leaders and executives like to mouth the words surrounding corporate culture. It is part of the code they all use with each other. Few of them, however, really know what the word means or even dare to understand the importance to their business. Let’s face it – corporate leaders and executives like to talk the talk but they rarely if ever understand what they...
There are a lot of talented CEOs. Some remarkable leaders, innovators and eloquent spokespeople for their companies. In several recent experiences, I have been befuddled by some CEOs. When a CEO addresses a global ethics and compliance staff or has the opportunity to address a large staff or division meeting, the CEO should take the opportunity to reinforce the company’s culture and compliance program message. ...
An increasing number of chief compliance officers report directly on a monthly basis to the Chief Executive Officer. As the compliance profession has earned independence and empowerment, CCOs are now part of the C-Suite and need to develop a positive relationship with the CEO to support the company’s ethics and compliance program. In doing so, CCOs need to ask themselves two important questions: (1) what...
We all tend to gloss over a critical requirement for an effective ethics and compliance program – tone-at-the-top. I hate to be dogmatic about the issue but, as Mel Brooks said in the Curb Your Enthusiasm (Season 4, Episode 1), “You either got it or you ain’t.” The same is true for the board, CEO and senior executive commitment to ethics and compliance. Every Chief...
There is no doubt that corporate boards operate under greater scrutiny. The trend is clearly to hold boards and individual members accountable. But this is not the result of government prosecution; rather, this trend reflects increased regulation and changes in investor and shareholder efforts to monitor corporate boards and CEOs. As corporate boards assume greater responsibility for supervision and monitoring of company activities, they have...
We all have heard the scenario involving a compliance professional. A new CCO joins a company with promises from the board, the CEO and senior executives of cooperation, compensation and support for a robust independent compliance function. The new CCO arrives with an idealistic spirit only to discover that he or she has been misled. Sure, the CCO has a title, and a nice salary,...
One very accurate indicator of a compliance program is the relationship between the CEO and the Chief Compliance Officer. If a CCO is repeatedly making excuses for a CEO who does not devote enough time to compliance, you can rest assured that the compliance program is nowhere near effective. Let’s start with the basics. Almost 60 percent of CCOs now report directly to the CEO....
For years, cyber security has been the province of IT specialist and technicians. Those days are long gone. If you ask a Board of Directors to identify a company’s most significant risk – cyber security is tops. That is no big surprise. When you consider the consequences of a cyber intrusion or a more likely breach, companies suffer serious reputational and financial harm. Directors, senior...
These are heady days for Chief Compliance Officers. Over the last 20 years, the CCO has moved from the backwater of corporate offices to the front and center of the power structure. We now have debates over the independence of the CCO from the legal function, the reporting obligations and the relationship between the CCO and the board. There is no question that CCOs have...
