From the SCCE:
In the recent Corporate Integrity Agreement between Pfizer and the Office of the Inspector General of the Department of Health and Human Services, Pfizer agreed that its Chief Compliance Officer will report directly to the CEO; will neither be nor be subordinate to the General Counsel or CFO; and will make periodic reports to the Audit Committee of the Board. Does it negatively impact a compliance program when the GC is also the head of ethics and compliance? To whom should the chief compliance and ethics officer report? And how can a company create the right level of independence for the compliance function?
In order to gather valuable benchmarking data for our members, the SCCE has compiled 9 short questions regarding compliance officer positioning. Please take a minute to answer the survey, then check back to view the valuable benchmarking data. Thanks very much for your participation and your important contribution to compliance and ethics benchmarking research.
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