The Corporate Compliance Committee is responsible for the periodic assessment and prioritization of legal compliance risk areas, the sharing of compliance program best practices, and the development of enterprise-wide tools and monitoring mechanisms to increase the efficiency and effectiveness of company-wide compliance activities.
Committee members are legal risk area subject matter experts and senior managers with compliance responsibility for specific risk areas. The members are appointed to the Committee by the Chief Ethics and Compliance Officer, who serves as Chair of the Committee. Business-based ethics and compliance officers serve as ex officio members. Members are expected to attend all meetings or designate a substitute.
Meetings and reports
The Corporate Compliance Committee meets quarterly to review compliance program activities. Members present progress reports on the status of the compliance efforts for their assigned risk areas, and whether there have been any changes to the risk area or their evaluation of the level of risk.
As part of the periodic risk assessment process Subject Matter Expert (SME) members provide written reports on their assigned compliance risk areas, covering the adequacy of corporate policies, instructions, procedures etc. which define and implement their programs; any significant regulatory, political, or legal changes in their area of responsibility; and any new risks to the company which need to be addressed.
Business-based ethics and compliance officers provide an annual assessment and supplemental compliance training plan for any additional compliance training needed in their organizations beyond the company-wide compliance training core courses.