The Chief Compliance Officer (CCO)

As a human being the CCO should be experienced, with integrity, should have rapid perception and should be intelligent. The word intelligence derives from the Latin “intellegere” and means “to understand” (literally to choose between”). He must therefore be able to recognize connections and convert them into actions. He should have a firmly anchored self confidence so that he remains steadfast even when the things go against him. For the person who occupies this position is quite certainly not “Everybody’s Darling”.

If he is really good at his job he will repay the expense incurred by the company many times over.

Within the company the CCO should ensure that the company, its managers and employees all comply with laws, national and international legal standards and procedures that are usually adopted in the industry.

He must also ascertain compliance with commitments of the management that are normally enshrined in a code specific to the company (Code of Conduct).

The job description of the CCO is unique and cannot be fulfilled merely by lawyers. A good CO is capable of thinking logically, strategically and interdisciplinarily and is able to adapt to constantly changing general conditions and convert them in the individual case to concrete recommendations for action and policies for implementation.

Because politics and industry agree that corruption and other offences against laws and the rules of our present company can cause serious damage, the growing demand for CCOs is inevitable and can be seen in the level of salaries in this professional group.
However, the acceptance of the CCO within the company will depend not least on whether the financial cost is kept as low at acceptable levelsand whether his contact with colleagues and superiors is as free of conflict as possible.

The structure of the compliance organisation is an indication of a possible slimming down of processes and savings in human resources, and with the information from it major impulses are generated for changes in the company
As a reliable partner he listens to the problems and concerns of the whistleblowers and performs his function as a consultant to the management. In principle no one is authorised to issue the CCO with instructions, neither the legal department, the internal auditing, controlling nor the risk management.
He reports exclusively to a board member and he is obliged to do so. The CCO must always take a global view of the company policy and decisions of individuals. For medium-sized businesses the duties of the CCO may be transferred to an external compliance officer for cost reasons,lack of specific expertiseor excessive expenditure. Areas of responsibility and functions may also be handed over to him from the existing company.