Earlier I considered the Compliance Oversight Committee. Today, I want to you to consider another compliance committee which could positively impact your compliance regime, the Regional Compliance Committee which is created at the regional level, to create more direct ownership, accountability, and valuable transparency.  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 business objectives are achieved in a legally compliant fashion.

This Regional Compliance Committee gives compliance a more thorough discussion at regularly occurring company operations meetings. Regional Compliance Committee provides a communication structures designed to facilitate communication up the chain and down the chain. It can give a CCO a more direct set of eyes and ears closer to the ground. Finally, the Regional Compliance Committee facilitates the compliance function greater visibility within the organization because compliance has been moved further into the middle and lower levels of the organization on a daily basis.

One of the key elements of the Committees are their makeup, which is Region centric. The Committee members are such regional leaders as: (a) the Executive Vice President of the Region or equivalent; (b) the Compliance Director for the Region; (c) the Legal Director for the Region; (d) the HR Director of the Region; (e) the Finance Director of the Region and/or audit personnel located in the Region; (e) the Supply Chain Director of the Region; (f) the Sales Director of the Region and (h) senior representatives of Operations in the Region.

The Regional Compliance Committee operationalizes compliance into the Company’s Regional operations where the business operates. This approach follows the Department of Justice mandate, articulated in the Department’s FCPA Pilot Program for companies to move the doing of compliance down into the business of the organization. The make-up of the Regional Compliance Committee, while including legal and compliance representatives, is also populated by representatives from other disciplines within the global organization, which allows a fuller, richer and more holistic approach to compliance advice.

It adds a dimension not often seen or even discussed in the compliance profession. The accountability and oversight down to the Regional level and the compliance monitoring, reviewing, assessing and recommending that is deemed to be necessary will provide additional endorsements up through the organization that it is actually doing compliance. The Regional Compliance Committee can provide a unique structure to perform these functions.

Key Takeaways

  1. A regional compliance committee can work to drive more efficient and more robust compliance into the region.
  2. All regional leaders should be on the committee.
  3. The regional compliance committee should liaise with other compliance committees.

For more information, check out my book Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program, which is available by clicking here.

 

 

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