Relatively few companies have made the formal designation of chief compliance or governance officer, which makes the job description difficult to codify. It also illustrates how the responsibilities of the CCO are often distributed around the organization, usually between the positions of general counsel and corporate secretary.

But according to The Conference Board in its “2003 Corporate Governance Best Practices” report, the formal designation is less important than whether the governance functions are accomplished: “Most important is whether corporate governance rises to the board level, governance functions are coordinated among departments and are accorded sufficient importance within the company.”