Compliance Program Management

Reduce Business Drag and
Increase Program Impact

In Search of Compliance
Program Effectiveness

An effective compliance and ethics program is a basic expectation of modern organizations. Compliance programs striving for effectiveness have focused on building their foundations (e.g., policies, training) and expanding their coverage and activity set.

While most companies have made progress this way, it typically requires employees to step outside their workflows and pass through numerous processes and approvals to satisfy compliance controls. These "bolt-on" compliance activities create burden for the business, confusion for stakeholders and—perhaps most importantly—are easier for employees to avoid.

Anti-bribery and corruption is a difficult area of risk for companies to handle in order to be successful in the current global environment.

Sonny Cave
EVP, General Counsel, Chief Risk and Compliance & Ethics Officer
ON Semiconductor Corporation

Compliance Stakeholders
Need a New Approach

This "bolt-on" approach is unsustainable—and an urgent problem to solve—as key stakeholders' demands evolve:

  • Regulators: Integrate compliance more into organization's operations
  • Boards: Coordinate reporting and risk narratives with other assurance functions
  • Business leaders: Streamline processes and demonstrate ROI
  • Employees: Reduce the effort burden of compliance 

At the same time, cost pressures on Compliance are growing. To do more with less, Compliance leaders must develop a clear action plan to identify and execute on the trade-offs required to best support program goals.

Put Compliance Process
In Business Process

Leading compliance and ethics programs reduce business drag and increase program impact by building compliance directly into the operations of the business. This means becoming a part of employees' standard workflow, rather than functioning as a separate process tacked onto employee processes and systems.

To achieve this, compliance leaders must change their programs in three ways:

  1. Design compliance to be part of business workflow 
  2. Coordinate compliance and related assurance activities
  3. Assess how well compliance is built in to the business

Every piece of your program needs to be tied to the actual operation… into the daily life of the corporation.


Hui Chen
Compliance Counsel
US Department of Justice

Effective Compliance:
Collaboration is Key

Before launching program enhancement initiatives, Compliance must first understand functional partners’ activities and use that knowledge to identify areas for closer cooperation. Collaboration at this level will increase program activities’ impact and efficiency while reducing unnecessary burden on employees.

To enable meaningful collaboration, compliance executives should ask functional partners a set of key questions to create visibility and assess feasibility.