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Every company is unique, and its compliance program must be too if it has any chance of working well, but there are still some common aspects that most high-functioning of The Foundation of Good Compliance & Governance. Compliance and governance can’t just be wedged into existing functions and reporting lines; integration must be carefully engineered so it effectively meshes with business lines and a wide variety of departments, from internal audit to HR, IT, and finance. At the same time, compliance must have the independence it needs to surface concerns, play a lead role in investigations, and influence culture. Those dual interests were an underlying theme at the latest Compliance Week executive roundtable, co-hosted with Boeing Co. in Dallas in November. Compliance executives from a wide range of industries and companies, including Boeing, GE Capital, AT&T, Dr Pepper Snappie, and American Airlines, shared strategies on structuring and organizing the compliance function. They all weighed in on what compliance and governance means to their organizations and how it flows through to various reporting lines. “We all struggle with and debate over where should all these different functions sit—compliance, enterprise risk management, audit, enterprise information governance, and corporate governance,” said Judy Carter, vice president for compliance and audit for BNSF Railway. The Foundation of Good Compliance & Governance. “There are so many common goals that run through each of these functions. The objective is to structure your organization so you can effectively leverage all of these efforts. Roundtable participants agreed that compliance officers tend to wear several hats and that it’s not always easy to move among the many different necessary roles. Staying on top of everything can be a challenge and as businesses grow or evolve, complications are even more pronounced. Eric Hinton, senior director of ethics and compliance for 7-Eleven, said his goal is to bring order to “pieces of compliance that live in a lot of different places.” The Foundation of Good Compliance & Governance. “We can improve that by consolidating and rationalizing it and making it more coherent across the enterprise,” he said. Within the corporation, effective interaction with other areas is a concern that Doug Cotton, managing director of American Airlines’ business ethics and compliance program had in common with other roundtable participants. Compliance oversight raises a thorny issue: “How far do we push without having them think we are trying to take over.” Buy-in from executive leadership alone doesn’t necessarily make that effort any easier. “We get really good tone from the top and have really good policies. The Foundation of Good Compliance & Governance.
The struggle is making sure everybody understands those policies,” Eric Bowman, chief compliance officer for Darling International, said. Diana Sands, senior vice president for the Office of Internal Governance at Boeing, described compliance at the aerospace giant as a journey. What originated as a response and enforcement function now has a “vision around enabling company performance.” The important question: “Can we gain a competitive advantage if we do it more effectively and efficiently?” In her role, Sands oversees Boeing’s compliance and ethics program. She is responsible for ethics, trade controls, compliance risk management, and the team of professionals who comprise internal audit. “In the beginning, it was all about setting up the appropriate structure and rules,” she said. “What we have evolved to is being an integrated business partner, a function that provides centralized and focused expertise in the field and is also integrated with the businesses.” By bringing multiple interests to the same table, the goal is to foster a seamless sharing of information among stakeholders, she said.