Another way to operationalize compliance is to have oversight moved out into regions. Such an approach can more effectively ensure employee and third party compliance with your Code of Conduct throughout a organization by integrating compliance into every aspect of a Company’s functions and generating the necessary information to continuously improve your compliance program. Such a regional compliance committee can operate on multiple planes to fully operationalize compliance in a company, augment existing internal controls and make the company a more efficient and profitable entity.

The formation of a regional compliance committee works to operationalize compliance through the creation of more direct ownership, accountability, and valuable transparency of your compliance regime.  This moves compliance down into all levels of the company’s operations.  This approach also significantly improves consistency of compliance execution and helps to ensure that all a company’s business objectives are achieved in a legally compliant fashion. Such a regional compliance committee can advise and provide information and insights to the CCO, receive compliance information from the corporate compliance function for the relevant region regarding applicable compliance requirements, industry standards, your Code of Conduct, as well a corporate compliance program as it relates to a region. A regional compliance committee should not have primary responsibility for internal investigations can report up any known compliance issues to the corporate compliance department.

A regional compliance committee is designed to promote clear and frequent compliance-related communication on related matters throughout the region and strengthen the company’s compliance culture.  It is valuable to the overall performance of the corporate compliance program within the region. It allows compliance topics to be more thoroughly discussed at regularly occurring operational meeting they have communication structures designed to facilitate communication up the chain and down the chain; allowing the CCO to have a more direct set of ‘eyes and ears’ closer to the ground. Finally, a regional compliance committee give the compliance function greater visibility within the organization because compliance has been moved further into the middle and lower levels of the organization daily.

Authority and Responsibility

There are multiple delineated responsibilities for a regional compliance committee. Some of these responsibilities can include:

• Assisting in identifying not only potential legal and compliance risks in the region but also reputational risks your company.
• Establishment of goals and metrics to measure against these legal and compliance goals in the region.
• Exercising oversight of the implementation and effectiveness of the company’s compliance program in the region. Additionally, to make recommendations to the CCO and suggest improvements to the compliance practices in the region.
• Reviewing and monitoring implementation of your Code of Conduct in the region and assisting in the identification of best practices, alternative strategies and local initiatives to enhance the compliance program.
• Assuring to the CCO and the senior leaders of operations that compliance goals and requirements are both established and communicated across the region.
• Advise management of its assessment of the corporate compliance program, ethics and compliance risks in the region and steps taken to both manage and lessen such risks.
• Reviewing the hotline complaints and other information to assure that appropriate steps are taken to modify the corporate compliance program to reduce identified ethics and compliance risks in the region.

The formation of a regional compliance committee operationalizes compliance into the region where the business operates. This sort of approach follows the Department of Justice mandate, articulated in the Evaluation for companies to move the doing of compliance down into the business of the organization. The make-up a regional compliance committee, while including legal and compliance representatives, is also populated by representatives from other disciplines within the global organization. This allows a fuller, richer and more holistic approach to not only compliance advice but reviews consistent with the Evaluation’s mandate of shared commitment by other functional disciplines within an organization.

It also adds a dimension not discussed nearly as often in the compliance profession as it should be going forward. The accountability and oversight down to the regional level and the compliance monitoring, reviewing, assessing and recommending will provide additional endorsements up through the organization that it is doing compliance. In compliance, it is execution where the rubber meets the road. This is the functional definition of operationalizing compliance.  

Three Key Takeaways

1. A regional compliance committee works to more fully operationalize compliance.
2. A regional compliance committee, properly staffed, evidences the shared commitment to compliance as required under the Evaluation.
3. A regional compliance committee is a two-way communications avenue, both inbound and outbound.

This month’s podcast series is sponsored by Oversight Systems, Inc. Oversight’s automated transaction monitoring solution, Insights On Demand for FCPA, operationalizes your compliance program. For more information, go to OversightSystems.com.

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