Consumer products giant Procter & Gamble ousted Chief Executive Officer Robert McDonald yesterday and announced that his predecessor Arthur Lafley will come out of retirement to take his old job back—and immediately I started to wonder what that will mean for P&G’s ethics and compliance function.
P&G is the largest company that I know of—$84 billion in annual revenue, 126,000 employees around the world—that does not have a dedicated chief compliance officer. Instead, the company has a cavalry of mid- and senior-level executives who address ethics and compliance. Nominally they answer into the legal function, but the more important idea is that no single person should “own” ethics and compliance. Rather, executives rotate into ethics and compliance duties from elsewhere in the business, stay there a few years, and then rotate back out into the field, presumably to keep spreading the gospel of good conduct throughout the whole corporation.
