Corporate Compliance & Ethics Data Survey Facts & Analysis In Partnership With 2015 Consero Group. Reproduction Prohibited.
INTRODUCTION Corporate Compliance & Ethics Data Survey Given the increasing volume of global regulations and internal corporate compliance policies, the role of the Chief Compliance Officer is more important and challenging than ever before. To meet the demands and risks of a complex regulatory landscape, the Chief Compliance Officer requires a well-designed overall compliance strategy, along with a strong compliance training program, an experienced team, and support from the rest of the business. Survey Structure And Methodology Consero s Spring 2015 Corporate Compliance & Ethics Data Survey Report, developed in partnership with Broad & Cassel, was produced in connection with Consero Group s April 2015 Corporate Compliance & Ethics Forum for Chief Compliance Officers from Fortune 1000 companies. While the survey was limited to 47 participants, the answers provide valuable insight into the challenges, concerns, and opportunities of this group of senior compliance executives. Table Of Contents 3 4 5 6 7 8 Budget & Resources Compliance Training Internal Investigations Compliance Strategy & Operations 9 10 11 Conclusion Consero Broad & Cassel 2 2015 Consero Group. Reproduction Prohibited.
BUDGET & RESOURCES Fifty-Seven Percent Of Chief Compliance Officers Do t Have Access To Necessary Resources. Two-thirds of Compliance executives surveyed reported an increase in both departmental budget (62%) and staff size (65%) over the last 12 months. Despite this increase, 57% of Chief Compliance Officers surveyed do not feel as though they have sufficient access to resources to manage their compliance programs effectively. In addition, the Compliance Officers were split when asked whether their departments were sufficiently integrated into corporate decision-making and strategy, with only 46% responding affirmatively. While Compliance Officers may require more access to resources and further integration into the corporate decision-making process, the increase in departmental resources over the past 12 months is a positive sign for the compliance function. Figure 1: How has your departmental budget changed over the last 12 months? Increased 62% Decreased 7% Did not change 31% Figure 2: How has your staff size changed over the last 12 months? 65% Increased 11% Decreased 24% change 3 2015 Consero Group. Reproduction Prohibited.
BUDGET & RESOURCES Figure 3: Do you have sufficient access to resources to manage your compliance program effectively? 43% 57% Figure 4: Is your compliance department sufficiently integrated into corporate decision-making and strategy? 46% 54% 4 2015 Consero Group. Reproduction Prohibited.
COMPLIANCE TRAINING A Majority (65%) Of Compliance Executives Use Metrics To Measure Their Compliance- Training Programs. Consero s January 2015 Corporate Compliance & Ethics Data Survey found that bribery and corruption is a top risk for Compliance executives this coming year. As such, it is not surprising that 67% of Compliance Officers surveyed have made bribery and corruption training mandatory for all the managers in their organization. The training programs of 63% of those surveyed are delivered mainly through a mixture of online and face-to-face methods. While 65% of Chief Compliance Officers use metrics to measure the effectiveness of these training programs, there remains some room for improvement in this area to ensure the efficacy of compliance within their organizations. Figure 5: Is bribery and corruption training mandatory for all managers in your organization? Figure 6: Do you use metrics to measure the effectiveness of your compliance-training program? 67% 33% 65% 35% Figure 7: How is your training program primarily delivered? 29% 9% 62% Online Face-to-face Mixed 5 2015 Consero Group. Reproduction Prohibited.
INTERNAL INVESTIGATIONS Ninety-Six Pecent Of Those Surveyed Have Conducted An Internal Investigation In The Past Year. The Chief Compliance Officer may be heavily involved with managing internal investigations within a company given his or her position of ensuring that employees comply with regulations and internal policies. An overwhelming majority (96%) of the Chief Compliance Officers surveyed reported that their company has conducted an internal investigation in the past 12 months. These investigations have certainly kept the compliance department busy, as 83% of Chief Compliance Officers reported that in-house counsel typically direct the internal investigations within their organizations. Only 4% use special outside counsel and 3% employ the use of regular outside counsel, while 10% seek their Board or one of its committees to direct such matters. Figure 8: Who typically directs internal investigations in your organization? 4% 3% 10% In-house counsel 83% Regular outside counsel 3% Special outside counsel 4% The Board or one of its committees 10% 83% Figure 9: Has your company conducted an internal investigation in the past 12 months? 96% 4% 6 2015 Consero Group. Reproduction Prohibited.
COMPLIANCE STRATEGY & OPERATIONS Only 20% Of CCOs Have The Proper Technology Infrastructure To Meet Their Compliance Needs. The top areas of focus for 20% of Chief Compliance Officers surveyed are overall compliance strategy, and training and communication. Regulatory changes, cybersecurity, and bribery/corruption matters closely follow these areas of focus for 16% of Compliance executives. A vast majority (80%) of those surveyed do not have the current technology infrastructure in place to meet the needs of their operations. It is thus surprising that only 10% mentioned technology as an area of focus in 2015, a figure that may increase over the next few years, given the apparent need for attention on cybersecurity and training. In addition, 52% of compliance departments conducted due diligence for a possible merger or acquisition in the past 12 months, which may indicate more involvement from the compliance side in corporate M&A activity. Given the various items on the Chief Compliance Officer s plate in the next year, it is fortunate that 72% of those surveyed feel as though their middle management promote a culture of compliance and ethics within their organizations. Figure 10: What are your top areas of focus in 2015? (Select all that apply.) Overall compliance strategy 20% Regulatory changes 16% Third-party management 12% Bribery/corruption 16% Technology integration 10% Training and communication 20% Cybersecurity 16% Other 6% 7 2015 Consero Group. Reproduction Prohibited.
COMPLIANCE STRATEGY & OPERATIONS Figure 11: Has your department conducted due diligence for a possible merger or acquisition in the past 12 months? 52% 48% Figure 12: Does your middle management promote a culture of compliance and ethics within your organization? Figure 13: Does your current technology infrastructure meet the needs of your compliance operations? 72% 28% 20% 80% 8 2015 Consero Group. Reproduction Prohibited.
CONCLUSION Lessons For The Industry The Corporate Compliance function is a dynamic and strategic role that requires extensive training and communication. Through the use of sufficient resources, both budgetary and human resources, the Chief Compliance Officer will be able to better serve the needs of the corporation in meeting the demands of regulations worldwide. While there is upward growth in the area of departmental resources, today s compliance departments seem to require more support and integration into corporate decision-making. The next year will see a focus on training and overall compliance strategy that will allow Compliance departments to provide optimum value to their organizations. 9 2015 Consero Group. Reproduction Prohibited.
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Broad and Cassel is one of Florida s most prestigious business law firms, serving clients worldwide from its offices in Boca Raton, Destin, Fort Lauderdale, Jacksonville, Miami, Orlando, Tallahassee, Tampa, and West Palm Beach. We provide full-service legal representation for individuals, public entities, and private enterprises from start-ups to Fortune 500 companies, including U.S. companies conducting business overseas, as well as foreign companies active in the U.S. Our lawyers know Florida, serving as trusted advisors on a diverse range of issues. Founded by Alvin Cassel and Shepard Broad in 1946, the firm now has more than 170 attorneys with extensive experience in a wide variety of practice areas, including: Business Litigation; Corporate and Securities; Construction Law and Litigation; Real Estate Development; Estate Planning and Trusts; Health Law; International Law; Land Use and Environmental Law; Taxation; Bankruptcy and Creditors Rights; Labor and Employment; Eminent Domain; Appellate Law; Public Finance and Capital Projects; and White Collar Defense and Compliance The attorneys of Broad and Cassel s White Collar Defense and Compliance Practice Group have more than 75 years of combined experience in representing individuals and institutions confronting all phases of criminal, civil and administrative fraud matters, from investigation through trial and appeal. Team members have been successful in the informal resolution of investigative matters and in prevailing at trial and on appeal. We also have experience in dealing with fraud matters in its many forms and with all its collateral consequences, such as federal and state sanctions and disciplinary matters, government debarment and exclusions and contractual relationships. Broad and Cassel s lawyers also understand the benefits of effective compliance for minimizing fraud, compliance and regulatory risks confronting business organizations. Our attorneys assist a broad range of organizations with internal compliance matters and strategies for managing organization compliance risks. We have successfully represented clients accused of Medicare, Medicaid and health insurance fraud; pharmaceutical fraud; securities fraud; general insurance fraud; bank fraud; bribery and kickbacks; tax fraud; embezzlement; criminal and civil RICO; bankruptcy fraud; perjury; money laundering; government procurement and contract fraud; Foreign Corrupt Practices Act matters; criminal and civil forfeitures and obstruction of justice. Broad and Cassel s attorneys offer clients the tools they need to proactively and reactively avoid criminal and civil exposure and protect their businesses, property and liberty. For more information, please visit us online at www.broadandcassel.com. 11 2015 Consero Group. Reproduction Prohibited.
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