It’s time to call it quits. The general counsel/chief compliance officer relationship debate, that is. The never-ending discourse as to whether the GC and CCO positions should be separate or can be combined; whether the compliance officer can report to the general counsel; whether one position, rather than the other, serves as the moral compass of the organization. And all of the absolutism that the positions must be structured “just so” in order to demonstrate compliance effectiveness or satisfy “best practices.”
In an increasingly compliance-conscious commercial world, thoughtful, law-abiding and ethical organizations are reaching their own, informed decisions as to how the GC-CCO relationship should work; how it can provide an effective best pathway for assuring adherence to law. As noted in a recent Corporate Counsel column, “GC v. CCO: The Big Debate,” credible survey results reflect a wide variety of corporate approaches to this important relationship. The rigid model promoted by some is not meeting with universal acceptance at companies that nevertheless share the same vigorous commitment to compliance.
