Corporate legal compliance officers and ethics officers have duties that vary from company to company.  Yet the legal compliance officer and the ethics officer have certain characteristic duties that appear almost always for each of them.

Compliance Offices vary greatly.  If the legal compliance officer (LCO) and ethics officer (EO) are supervised by one individual, there are many efficiencies attained. The combined supervisory official commonly is known as the Chief Compliance Officer (CCO)

What follows is a sample position description for a Chief Compliance Officer

Remember, this is an exemplar only; each company is unique and has unique needs.  Many companies will split the duties of Legal Compliance and Ethics Compliance between two officers, commonly a General Counsel and an Ethics Officer.  Nevertheless, at some point in every company, there should be an individual of high authority who coordinates and supervises both legal and also ethics compliance.

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Exemplar for Short Job Description of a Chief Compliance Officer

The Chief Compliance Officer (CCO) oversees the Corporate Compliance Program.

The CCO is the head of the Corporate Compliance Office of the company.

The Corporate Compliance Office functions as:

  1. an independent and objective body that reviews and evaluates compliance issues,
  2. the organizing body establishing procedures and monitoring compliance with the rules of government,
  3. the originator and monitor of company compliance policies and behavior to meet the company’s Standards of Conduct,
  4. a channel of communication to receive and direct compliance issues to appropriate resources for investigation and resolution, including being an internal resource with which concerned internal or external parties may communicate concerns about possible illegal or unethical behavior within the company,
  5. a principal channel of communications of confidential legal advice and communications between corporate counsel and the company, and
  6. a member of the company’s crisis management team,

The Chief Compliance Officer acts as staff to the CEO and Board of Directors’ Corporate Compliance Committee by:

  1. monitoring and reporting results of the compliance/ethics efforts of the company, and
  2. providing guidance for the Board and senior management team on matters relating to compliance.

The Chief Compliance Officer, together with the Corporate Compliance Committee, is authorized to implement all necessary actions to ensure achievement of the objectives of an effective compliance program.

GENERAL DUTIES AND RESPONSIBILITIES

The Chief Compliance Officer:

  1. Develops, initiates, maintains, and revises policies and procedures for the general operation of the Compliance Program and its related activities to prevent illegal, unethical, or improper conduct.
  2. Manages day-to-day operation of the Compliance Program.
  3. Develops and periodically reviews and updates Standards of Conduct to ensure continuing currency and relevance in providing guidance to management and employees.
  4. Collaborates with other departments (e.g., Risk Management, Internal Audit, Employee Services, Legal) to direct compliance issues to appropriate existing channels for investigation and resolution.
  5. Consults with the Corporate attorney as needed to resolve difficult legal compliance issues.
  6. Initiates and monitors systems to maintain confidentiality and privileged status of legal communications and intellectual property of the company.
  7. Responds to alleged violations of rules, regulations, policies, procedures, and Standards of Conduct by evaluating, or recommending the initiation of, investigative procedures. Develops and oversees systems for handling of violations.
  8. Acts as an independent review and evaluation body to ensure that compliance Issues/concerns within the organization are being appropriately evaluated, investigated and resolved.
  9. Monitors, and as necessary, coordinates compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends.
  10. Identifies potential areas of compliance vulnerability and risk; develops/implements corrective action plans for resolution of problematic issues, and provides general guidance on how to avoid or deal with similar situations in the future.
  11. Provides reports on a regular basis, and as directed or requested, to keep the Corporate Compliance Committee of the Board and senior management informed of the operation and progress of compliance efforts.
  12. Ensures proper reporting of violations or potential violations to duly authorized enforcement agencies as appropriate and/or required.
  13. Establishes and provides direction and management of the compliance Hotline.
  14. Institutes and maintains an effective compliance communication program for the organization, including promoting (a) use of the Compliance Hotline; (b) heightened awareness of Standards of Conduct, and (c) understanding of new and existing compliance issues and related policies and procedures.
  15. Works with the Human Resources Department and others as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees as well as ongoing training for all employees and managers.
  16. Monitors the performance of the Compliance Program and relates activities on a continuing basis, taking appropriate steps to improve its effectiveness.
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