Compliance &Ethics - Society of Corporate Compliance and Ethics

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RegisteR noW foR sCCe’s 2013Compliance & Ethicsregional ConferencesUpper NortheastNew York, NY • May 17Network locallyand get the latest on thekey challenges facing thecompliance communitySCCE Regional Compliance & Ethics Conferences provide aforum to interact with local compliance professionals, shareinformation about our compliance successes and challenges, andcreate educational opportunities for compliance professionalsto strengthen the industry.Attendees learn about current regulatory requirements, governmentenforcement initiatives, and the management of effective complianceprograms; and meet and network with other complianceprofessionals locally.Who should attend? Compliance officers, in‐house and outsidegeneral counsels, privacy and security officers, regulatory affairs,VPs and directors, government agency staff.Upper West CoastSan Francisco, CA • June 21alaskaAnchorage, AK • June 27–28soUtheastAtlanta, GA • November 1soUthWestDallas, TX • November 8NeW eNglaNdBoston, MA • November 15Learn more at www.corporatecompliance.org/regionals
Featureby C. J. Rathbun, CCEP, FLMI, HIA, AIRC, ACSYou’ve identified acorporate risk—what next?»»The company’s choices in response to an identified risk will depend on its risk tolerance.»»The CCO’s considerations should include how mitigating the risk will affect everyone from the board room to the mailroom.»»The CCO’s report should be carefully designed for its target audience.»»Internal procedures may need to be changed to prevent future risks.»»Proactive monitoring and/or auditing will help you catch problems before they become issues.RathbunThe scope of risk management extendsall the way from the boardroom to themailroom. The overall impact to theorganization, though, is first addressed at themanagement level by the chief complianceofficer (CCO). Once the board or chief executiveofficer has determined how thecompany will address any specificrisk, much of the planning and implementationresponsibility falls back onthe CCO’s shoulders.After your company identifies arisk, management will consider atleast these three dynamics beforemaking its choice of actions.1. The severity of the risk weighed againstthe company’s appetite for risk.2. How the company has performed in thepast on managing similar risks and if so,what the impact might be on the companyif the risk actually occurred.3. The probability or likelihood of the riskevent occurring.Shaping the compliance reportWhat considerations, then, should go intopreparing your compliance officer’s reportto the decision-making group on this newlyidentifiedrisk? The report should be shapedby answers to the following questions.··Who is the audience? Is it the board ofdirectors? The CEO? Or does it beginwith other C-suite executives? What isthe trust level that has been establishedwith that audience? Sometimes the audiencemay even be the regulatory bodythat previously examined your organizationand wants you to provide afollow-up report.··What is the organizational culture?How is a decision of this dimension usuallymade? How much detail does theaudience expect? What stories or exampleswill illustrate it best?··What reputational risk for the companyshould be anticipated? Would the companybe comfortable with this decisionbeing published in The Wall Street Journal,for instance?··What should be incorporated into thereport? What other business concerns,financial pressures, and legal liabilitieswill it include?··How should the report be presented?In what format or with what technology?Although this factor may seem a lessimportant consideration than the others,it will become increasingly more importantas generations in the board roomand C-suite change.Compliance & Ethics Professional May/June 2013+1 952 933 4977 or 888 277 4977 www.corporatecompliance.org 33
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Page 23 and 24: Boehme of Contentionby Donna Boehme
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Page 31: The Art of Complianceby Art Weiss,
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Page 37 and 38: Featurecompliance audits are alread
Page 39 and 40: Empirically Speakingby Leslie Altiz
Page 41 and 42: Featureby Steve CarrMind the gap!Wh
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Page 45 and 46: View from the Front Linesby Meric C
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Page 55 and 56: y Frank J. NavranYou can’t cure s
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Page 77 and 78: sTakeawaysMay/June 2013Compliance &
Page 79 and 80: Get expert guidance with:The Comple

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