The Six Elements of an Effective Compliance Program: Part 2 – Governance and Structure: Ensuring a Strong and Functional Compliance Program

Welcome to a special five-part podcast series, The Six Elements of an Effective Compliance Program. This podcast series is sponsored by StoneTurn. To celebrate Corporate Compliance and Ethics Week, we will consider each of the six elements required for an effective compliance program. They include: Risk Assessment, Governance and Structure, Policies Procedures and Controls, Training and Education, Oversight and Reporting, and Response and Enhancements. Over this five-part podcast series, I will be joined by Stephen Martin and Valerie Charles, Partners at StoneTurn and Toby Ralston and Jamen Tyler, Managing Directors at StoneTurn. In this second episode, I visit with Stephen Martin on compliance program governance and structure. Highlights include:

·      A CCO must have access and expertise. Who should a CCO have access to and what should be a CCO’s level of expertise?

·      A compliance function must be adequately resourced programs – what does this mean in practice? How much budget should your compliance program have? What should be your compliance function head count? What about those outside the compliance function that assist compliance?

·      Why should a Board have compliance expertise? What does the Department of Justice’s 2020 Update to the Evaluation of Corporate Compliance say about compliance expertise on the Board?

·      Why should there be a Compliance Committee, separate and apart from the Audit Committee?

·      Why should the Compliance Committee on the Board have a Charter?

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