Effective Compliance and Ethics Programs for the Small Law Department Doing

Effective compliance and ethics programs for the

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“Effective Compliance and Ethics Programs for the Small Law Department - Doing More with Less” ACC InfoPAK SM
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Effective Compliance and Ethics Programs for the Small Law Department – Doing More With Less Copyright © 2010 Corpedia, Inc., and Association of Corporate Counsel 30 Introduction The organization of the compliance function may be structured along lines that make the most sense for the company. It should, however, take into account a number of considerations that are reflected in the proposed structures: the Board and senior management have oversight responsibilities for the function; individuals responsible for the day-to-day operations of the function should report to the Board (or appropriate subgroup); individuals responsible for the day-to-day operations of the function should have “appropriate authority”; and the structure should address conflicts of interest (e.g., overseeing the compliance of a supervisor).
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For more ACC InfoPAKs, please visit 31 Organizational Structure #1 Compliance Organization within Legal Department where Chief Legal Officer (CLO) has day-to-day responsibility for operation of the Compliance Program and is also the Chief Compliance Officer. (CCO). CEO CCO and CLO Audit Committee of Board Staff Staff
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Effective Compliance and Ethics Programs for the Small Law Department – Doing More With Less Copyright © 2010 Corpedia, Inc., and Association of Corporate Counsel 32 Organizational Structure #2 Compliance Organization within Legal Department where Chief Legal Officer does not have day- to- day responsibility for operation of the Compliance Program, but is Chief Compliance Officer. CEO CCO and CLO Audit Committee of Board VP for Compliance with responsibility for day-to-day operation of Compliance Program Staff Staff
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For more ACC InfoPAKs, please visit 33 Organizational Structure #3 Stand alone Compliance Organization where some compliance functions have direct reporting relationship elsewhere with dotted line reporting to CCO. CEO HR Audit Committee of the Board CCO CLO Treasurer Compliance Officer for Anti-Money Laundering Associate General Counsel for Compliance (provides counsel to CCO) Field Compliance Officers Compliance Officer for Fair Employment Matters
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Effective Compliance and Ethics Programs for the Small Law Department – Doing More With Less Copyright © 2010 Corpedia, Inc., and Association of Corporate Counsel 34 Organizational Structure #4 Stand alone Compliance Organization where all compliance functions report to CCO. CEO CCO Audit Committee of Board HR CLO Treasurer Compliance Officer for Fair Employment Matters Compliance Officer for Anti-Money Laundering Field Compliance Officers
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For more ACC InfoPAKs, please visit 35 Organizational Structure #5 Compliance Organization for small company where Compliance Program is operated from within the Board by Independent Director.
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