The Relationship between the Board of Directors and the Compliance and Ethics Officer
The relationship between the compliance and ethics officer and the board of directors is both essential and often under developed. When the first version of the survey was fielded in 2010, many compliance professionals were struggling with how to manage what was to many a very new relationship.
Since then a number of factors have changed the dynamic. The Yates memo and increased scrutiny of individual (vs. corporate) actions gained the attention of senior leaders. Later, the Criminal Division of the US Department of Justice issued questions for prosecutors to use as guidance when evaluating compliance programs. Included in them were several about the activities of the board in overseeing the compliance and ethics programs.
To assess how the relationship between the compliance team and the board had evolved, as well as to examine issues of compliance officer influence, the Society of Corporate Compliance and Ethics and Health Care Compliance Association fielded this survey in 2014 and again in 2018.