Compliance with a Purpose

by Michael Volkov

missionChief compliance officers are under intense pressure.  They are being watched inside every company to make sure they deliver on their “compliance” program, and outside observers are ready to comment on any misstep or breakdown in corporate compliance.

It is a wonder that CCOs can get their job done.  They are pulled in a million directions, given inadequate resources, and held accountable for an unrealistic level of performance.  CCOs have to be careful not to overreact to this pressure.  They have to keep focus on what their job is and how they can best accomplish their purposes.

In this environment, CCOs have to avoid easy but meaningful measures of performance.  Instead, they need to establish relevant measures of their compliance program.

Sometimes it is easy to just measure what is easy to collect.  My favorite example of “easy” metrics is the number of complaints received on a hotline.  The number of complaints can be argued to reflect contradictory trends – a lot of complaints means employees believe in the speak up culture and hotline system, so therefore, the program is a success.  Conversely, a CCO could argue that an increase in the number of calls coming in on the hotline means that employees are unhappy and the culture is deteriorating.

effective6Similarly, CCOs may point to the number of employees being trained or the number of training programs conducted to reflect a success in a compliance program.  Of course, there is an obvious point to training  but the number of training programs attended by an employee does not really measure whether the employee understood the program, integrated it into his or her activities, and then adhered to the standards outlined in the training program.

CCOs have to look for and develop meaningful measures of their compliance program.  Once designed, they have to use these measures to inform their compliance program – whether it is to develop new policies, new approaches or refinements to their compliance program.

We all look for easy answers to complex problems.  Unfortunately, the world of compliance does not operate so easily.  Measures are hard to find and difficult to justify.  Relevance is a tough standard when looking at a compliance program.

In the face of overwhelming responsibilities, CCOs have to prioritize what they do and how they spend their resources.  Accurate measurements of a corporate compliance program help CCOs to allocate their limited resources most efficiently.

leveraging2CCOs have to solve this problem early in the design and implementation of a compliance program.  They need to focus on the culture of the company as the most reliable indicator of a compliance program.

A company that has a culture of ethics is in the best position to avoid serious legal and compliance risks.  CCOs know that and have to focus on that issue.  Once they do, the measurement of their compliance program will be tied to program improvements and refinements.


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

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.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):

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.


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 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:

- 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.