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.
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
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
Exemplar for Short Job Description of a Chief Compliance
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:
- an independent and objective body that reviews and evaluates compliance
- the organizing body establishing procedures and monitoring compliance with
the rules of government,
- the originator and monitor of company compliance policies and behavior to
meet the company’s Standards of Conduct,
- 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
- a principal channel of communications of confidential legal advice and
communications between corporate counsel and the company, and
- 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:
- monitoring and reporting results of the compliance/ethics efforts of the
- 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:
- 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.
- Manages day-to-day operation of the Compliance Program.
- Develops and periodically reviews and updates Standards of Conduct to
ensure continuing currency and relevance in providing guidance to management
- 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.
- Consults with the Corporate attorney as needed to resolve difficult legal
- Initiates and monitors systems to maintain confidentiality and privileged
status of legal communications and intellectual property of the company.
- 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.
- Acts as an independent review and evaluation body to ensure that
compliance Issues/concerns within the organization are being appropriately
evaluated, investigated and resolved.
- Monitors, and as necessary, coordinates compliance activities of other
departments to remain abreast of the status of all compliance activities and
to identify trends.
- 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.
- 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.
- Ensures proper reporting of violations or potential violations to duly
authorized enforcement agencies as appropriate and/or required.
- Establishes and provides direction and management of the compliance
- 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.
- 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.
- Monitors the performance of the Compliance Program and relates activities
on a continuing basis, taking appropriate steps to improve its effectiveness.