Building a World-Class Compliance Program: Best Practices and Strategies for Success

Appendix B. Sample Compliance Program Charter

Compliance and Ethics Leadership Council, 2005

CONTENT OF PROGRAM CHARTERS

Program charters are intended for internal stakeholders, providing visibility into the structure and objectives of the program. Charters aid in the management of the compliance and ethics program by clearly defining the following:

• Role of the compliance and ethics office and responsibilities of individual staff

• Reporting relationships of the Compliance and Ethics Officer

• Protocols for development and dissemination of business conduct standards and procedures to stakeholders

• Guidelines for monitoring and auditing of the Compliance and Ethics program

• Guidelines for reporting of business conduct allegations and advice requests (managing a whistleblower program)

• Guidelines for investigating alleged violations

• Role of the Audit Committee of the Board of Directors (or other committee to which the Compliance and Ethics Officer reports)

• Delivery schedule for compliance and ethics training

KEY PRINCIPLES

Organization and Independence

The Compliance and Ethics Officer is accountable to the Chief Compliance Officer and the Audit Committee with respect to the activities performed by the Compliance and Ethics Office. The Compliance and Ethics Office reports to the Chief Executive Officer and shall have direct access to the Audit Committee and shall take directly to the Chairman of the Audit Committee matters of sufficient magnitude and urgency to require immediate attention. As a matter ...