CCO’s Be Careful What You Ask For — You Just May Have It

by Michael Volkov
Contact

be carefulThe old adage has taken hold in the compliance field – “Be careful what you ask for, you just may get it.”

Compliance professionals are finally getting the respect they deserve.  They still have a long way to go.  General Counsels, Internal Auditors, Human Resource professionals are not going to accept the elevation of compliance professionals lying down.

The corporate world is filled with back-stabbing, intrigue and petty jealousies – don’t kid yourself to the contrary.  When one position rises, others are sure to be jealous or want to see failure.

CCOs have to ignore the pettiness of he corporate world.  They can always soothe themselves by thinking it could be a lot worse – they could be in academia, where the old saying applies, “Competition in academia is so vicious because the stakes are so low.”

For CCOs, the stakes are large.  CCOs have been arguing for years for more authority, resources and independence.  They are slowly getting just what they asked for.  Now is the time for CCOs to deliver.

Donna Boehme, a champion for the compliance profession, has written a terrific article available here, outlining important steps that every CCO should take to help instill an ethical culture.  (Here)

Just what are they supposed to deliver?    I hope everyone understands that CCOs are not guarantors of compliance.  They create and implement processes that are designed to minimize risk – the key word being “minimize,” not eliminate.

On the flip side, CCOs are promoters of an ethical culture.  They are politicians, evangelists, financial analysts, and everything they can roll into their job description.  They have to spread the word on corporate culture.be careful5

The fact is that CCOs have a positive message and they should stick to it.  People respond well to positive messages.

The same goes for a company’s internal politics.  Senior executives, managers and employees want to believe in their company; they want to embrace ethical conduct.  Everyone wants to “do the right thing.”  (Be careful of those who do not, they are sure to bring you down – they are the dark side of corporate governance).

The CCO’s message should tap into this powerful need in the corporate gestalt.   The positive message is the one that brings about positive financial results, greater sustainability and improved morale.  Each of these factors contributes to the other.

In the end, the CCO is part politician, part cheerleader, and part psychologist.  They have a schizophrenic task – on the one hand, they promote a positive message; on the other hand, they enforce the Company’s code of conduct; and on yet another hand, they have to prevent an enforcement action from a breakdown in compliance controls.

CCO’s asked for authority and they have it (or are getting it).  They are still fighting for the be careful6resources they need.  That will come – companies have no choice.

The real test for CCOs in the next five years is straightforward – they have to produce.

How and what they produce, is the next issue to be defined.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Michael Volkov, The Volkov Law Group | Attorney Advertising

Written by:

Michael Volkov
Contact
more
less

The Volkov Law Group on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Privacy Policy (Updated: October 8, 2015):
hide

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.

Security

JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at info@jdsupra.com. In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at: info@jdsupra.com.

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.