An organization should assign a specific high-level individual, or a committee that includes a sufficiently high-level individual, to have direct, overall responsibility for the strategic design and operation of the program. Such individuals ("strategic personnel") must be given direct access to the board and adequate resources and authority to set policy and carry out their responsibilities. Strategic personnel should be of high integrity, ethics and competence.
Principles
> Explicit responsibilities
> Direct communication with the board
> Sufficient authority to set policy and allocate resources
> High integrity
> Competent
> Evaluated
> Integrated with the business
Business Objectives
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To ensure that specific individuals within high-level management of the entity are assigned direct, overall responsibility for the implementation and effective operation of the program
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To ensure that the entity's compliance and ethics activities are adequately staffed and appropriately managed
Considerations
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Periodic communications from the Board of Directors and the CEO, supporting the program, can help to build confidence in the program and its importance
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Establishing individuals as champions to develop and maintain visibility and commitment to the program can help to "sell" the program internally
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Not all entities are of the size or scope of operations to require dedicated full-time compliance personnel
Critical Success Factors
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Clearly defined roles/responsibilities
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Adequate authority
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Adequate independence
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Adequate resources
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Identified informal leaders in addition to those with formal leadership roles
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Ability to set policy