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 compliance program is an interdependent function that gains exponentially from coordination and cooperation with key functions. CCOs have to be politicians and they have to develop effective interpersonal skills. Without an ability to connect with other individuals in a company, a compliance program will suffer some real and substantial difficulties. Compliance officers have to develop a target list of coordinators and cooperators. A CCO...
Chief compliance officers are politicians and have to possess great interpersonal skills. They have to “get along” and persuade key constituencies — most especially their business partners – to commit and devote time and resources to ethics and compliance. In order to operationalize their programs, CCOs have to build relationships with important partners – human resources, legal, internal audit, procurement, and finance. Up to this...
