Welcome back to the podcast, Grib, Swindle, or Steel.

I'm Alexandra Rogge, and today we're talking about how to secure and maintain board support for your compliance program.

My guest is Jeff Cottle.

Jeff is a partner at Norton Rose Fulbright, where he focuses on compliance program

design and implementation and compliance issues associated with mergers and acquisitions. Prior

to joining his firm, Jeff held several senior in-house positions in a variety of industries.

Jeff, thank you for joining me.

My pleasure.

I'd like to walk through the issues raised by board buy-in or lack of board buy-in, more or less chronologically.

But first, what does optimal board support look like to a compliance officer?

Yeah, I think optimal board support is about access.

And therefore, I think the organizational design of a compliance function is critical.

It's an issue that many companies get wrong, either would say accidentally, sometimes deliberately for all kinds of reasons.

But I do think getting organizational design set up such that it maximizes access for the CCO

to an important and relevant board member in the field of compliance is absolutely critical.

Well, maybe we should spend a minute on that now then. That design, can you give us an overview?

I know that different companies handle this in a lot of different ways, but if you were setting out to

design this optimal access, what would it look like?

Yeah, so unfortunately, there are two competing sort of imperatives when it goes into

design of where to put your compliance officer.

There's the somewhat critical issue of privilege, which most would say requires some degree of reporting into the general

counsel. And that sometimes is at odds with the other critical imperative, which is access.

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