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In [Part 1] Compliance Management Success Kit, the author outlined four important steps to establish focused and dynamic compliance processes every CCO should follow to successfully manage a company’s compliance program. This post looks at the first of the four steps on the way to achieving successful compliance management.
Define Certain Key Terms, and Position the Compliance Role
You are welcomed with open arms. The CEO’s introduction: “This is Jane (or Joe) and s/he is here to keep us compliant” – or – “We want to underscore our commitment to compliance, and that will be Jane’s (or Joe’s) responsibility…” Well intentioned – yes. But do you and the CEO have a common understanding of what the scope of “compliance” extends to under the company’s particular facts and circumstances, what it means to be “compliant”, or what your “responsibility” does and does not cover?
- Define Key Terms
It’s critical that a common understanding exists among you, management and the Board concerning what “compliance” means in this case, and what your role is with respect to the company’s risk universe. Similarly, make sure that the organization at all levels understands that compliance is a shared responsibility, and that your obligations are to lead and manage the compliance program – but not to act as guarantor that the company is, in fact, fully compliant.
- Position the Compliance Role
Parallel with appropriately educating your colleagues about the compliance side of things, broadcast early and often that you are there to support the business and to help drive good business. Change what may be the initial “cop” perception to “sales facilitator” and make sure that a cooperative rather than a hostile relationship is established between the sales and the compliance department. Go out of your way to say “yes”, if possible, and to take time out of existing processes that slow up the sales process. Valuable goodwill and acceptance can be generated by these visible signs that you understand that compliance is there to support the business, and not the other way around.
Now you have clearly defined key terms as ‘compliance’ and made sure that the management, the sales department and other employees all take part in upholding a compliant status within the company. You have also managed to establish your role as a compliant officer, proactively contributing to a sustainable sales strategy. The next step is then to leave the office chair and get engaged with the staff and with other local stakeholders to make your risk assessments. Next week’s post will look closer at step two: Namely, “Preparing for foreseeable challenges”.