The regional compliance committee should be created at the regional level and is designed to create more direct ownership, accountability, and valuable transparency. This operationalizes compliance by moving it down into a more direct level of a company’s operations. This approach also significantly improves consistency of compliance execution and helps to ensure that all business objectives are achieved in a legally compliant fashion.
This structure has several advantages. A regional compliance committee gives compliance a more thorough discussion at regularly occurring company operations meetings. It provides a communication structures designed to facilitate communication up the chain and down the communication chain. It can give a CCO a more direct set of eyes and ears closer to the ground. Finally, the regional compliance committee facilitates the compliance function greater visibility within the organization because compliance has been moved further into the middle and lower levels of the organization daily.
One of the key elements of a Regional compliance committee is their makeup, which is Region centric. The committee members are such regional leaders as: (a) the EVP of the region or equivalent; (b) the compliance director for the region; (c) the legal director for the region; (d) the HR director of the region; (e) the finance director of the region and/or audit personnel located in the region; (e) the supply chain director of the region; (f) the sales director of the degion, and (h) senior representatives of operations in the region.
The regional compliance committee operationalizes compliance into the company’s regional operations where the business operates. This approach follows the Department of Justice mandate, articulated in the Department’s Evaluation of Corporate Compliance Programs for companies to move the doing of compliance down into the business of the organization. The make-up of the regional compliance committee, while including legal and compliance representatives, is also populated by representatives from other disciplines within the global organization, which allows a fuller, richer, and more holistic approach to compliance advice.
It adds a dimension not often seen or even discussed in the compliance profession. The accountability and oversight down to the regional level and the compliance monitoring, reviewing, assessing, and recommending that is deemed to be necessary will provide additional endorsements up through the organization that it is actually doing compliance. The regional compliance committee can provide a unique structure to perform these functions.