CECO Case Studies
Read Case Studies from Chief Ethics and Compliance Officers
Case Study 1
1. Please tell us about your background prior to your current role.
I have a legal background, primarily in government contract law and Litigation.
2. What is your official job title?
Senior Vice President, Business Practices & Chief Compliance and Risk Officer
3. Please describe your general job responsibilities.
My general job responsibilities include running the compliance program for the company, of which a key part is developing awareness for compliance and ethics. While records and information management is also a key component, just as critical is helping management drive tone at the top. In addition, our organization has a system is in place that investigates wrongdoing. We also oversee and direct the company resources employees can use to raise issues which include our Helpline/Hotline and Ombudsman programs. Our organization is also responsible for: the Business Continuity program; the ethics and compliance training program (anti-trust, government contracting, ethical decision making, etc.); the Crisis Management program; the Export program; the Privacy program; and the Risk (ERM) program (getting every business unit to identify manage and mitigate their risks).
4. To what extent do you have adequate resources to carry out your duties?
I feel that I have both the adequate budget and right level of responsibility within the company to get the job done.
5. To what extent do you have adequate authority?
I am part of the company’s senior leadership and am on every senior management committee.
6. To whom do you directly report? Do you have a dotted line reporting relationship with anyone else in your organization?
I have a solid line reporting relationship to the chairman of the audit and compliance committee of the board of directors and the Executive VP for Global Risk and Compliance. I also report findings to the board and to management (CEO) on a frequent basis.
7. Who hires/fires you?
I am hired by management with the approval of the board. I cannot be fired without approval of the board.
8. Who sets your performance objectives?
Performance objectives are set by the EVP for Risk and Compliance.
9. What are the benefits and challenges of your reporting relationship?
A benefit of the reporting relationship is the sense of independence; I am, in effect, communicating with everybody in management and the Board of Directors. This is one advantage of having a direct connection to the board. However, this advantage only becomes real when management (CEO, CFO, etc.) is not listening. One would hope that this type of relationship with the board is what always happens. It should only be a lifeline.
Case Study 2
1. Please tell us about your background prior to your current role.
I have a background in theology and ethics.
2. What is your official job title?
Vice President/Corporate Responsibility Officer.
3. Please describe your general job responsibilities.
See corresponding job description.
4. To what extent do you have adequate resources to carry out your duties?
I believe the current level of resources is adequate to carry out the current expectations of my position.
5. To what extent do you have adequate authority?
I have adequate authority to address any misconduct that could occur, at any level of the organization, whether board member of senior executive.
6. To whom do you directly report? Do you have a dotted line reporting relationship with anyone else in your organization?
My original job description states that I report to the Chair of the Audit and Compliance Committee, with an administrative reporting relationship with the CEO (as a practical matter, this meant that the CEO filled out my performance evaluation). This was changed one year ago: now I report to the Chair of the Board, who fills out my performance evaluation. I was also appointed to the Executive Management Team; this is the 14 member team, chaired by the CEO, who oversees all aspects of managing the organization.
7. Who hires/fires you?
Chairperson of the Board of Directors.
8. Who sets your performance objectives?
Chairperson of the Board of Directors. Some input is provided by the CEO.
9. What are the benefits and challenges of your reporting relationship?
The benefits of my reporting relationship are threefold: I have sufficient authority to address misconduct at any level of the organization; I have sufficient independence to address any kind of corporate responsibility related matters, which is illustrated by my presenting to the board last year for 90 minutes and this year for 120 minutes, in addition to my quarterly reporting to the Board Audit and Compliance Committee; and I have an extensive and meaningful connection with Operations, which is illustrated by the fact that the COO serves on my Advisory Board, I serve on the Executive Management Team, and I work closely and directly with all of our business unit presidents.
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