What is an "effective" Compliance Committee?

The role an internal Compliance Committee - which is deemed to be "effective, robust and meaningful" in the eyes of both internal and external observers - is to ensure that the organization (HQ, Regional or Local) adheres to applicable Laws, Regulations, Corporate Codes, Policies and Standards issued by self-regulatory bodies in keeping with expected industry practices.

An effective Compliance Committee should develop procedures and practices which align with the following key tenets:

1. The observance by all employees to the Code of Conduct in force;
2. The ethical and fair treatment for all employees and third parties;
3. The ethical promotion of products and interaction with Stakeholders;
4. Good business practices and observance of stricter standards against bribery, corruption, money laundering and other crimes.

The Committee should be comprised of members from the Leadership Team, with a typical composition providing for: a minimum of three (3) members, mandatorily including the Chief / Regional Compliance Officer or the Inter / Area President, in conjunction with either the GC / Regional Legal Counsel as well as the CFO for any decision making.

Ideally, the Compliance Committee should hold regular (monthly or bi-monthly) meetings and take formal Minutes which are “actioned on” by appointed personnel.

Topics for discussion by the Committee might include any of the following “internal controls” and / or initiatives dealing with the following subject matter:

1. Operating Environment
2. Corporate Risk Management
3. Prevention
4. Detection
5. Correction

Accountability in "decision-making" and "agreed upon actions" is held by all Committee Members. In turn, decisions and actions which are taken outside of the recognised framework are the responsibility of the self-appointed initiator.