The sample statement below appears in the Society for Corporate Compliance and Ethics’s The Complete Compliance and Ethics Manual 2024.[1]
Sample Compliance Committee Member Confidentiality Commitment
I understand and agree that, in connection with the performance of my duties as a member of the compliance oversight committee, I will be engaged in activities of a confidential nature, including, but not limited to, participating in reviews and evaluations of internal investigations, evaluations, and self-evaluations of the policies, practices, and procedures of this organization.
I further understand that, in this capacity, it is likely I will receive and/or become privy to information of a confidential nature, including, but not limited to, financial statements; trade secrets; strategic plans; contracts with private parties; employee performance information; and other documents and statistics relating to compliance with policies, procedures, statutes, regulations, and other information of a confidential nature.
I further understand it is likely I will be called upon to evaluate such information, against our organization’s policies, and may also be privy to legal advice provided to the organization about applicable laws and regulations. I understand that my position as a member of this committee is one that demands the highest trust and that the organization’s policies and procedures, as well as, in some instances, specific statutes, regulations, and governmental policies, protect the confidentiality of certain records and information that I will be reviewing and prohibit their disclosure in any manner.
In addition to any duty of confidentiality or nondisclosure imposed on me by specific statutes, regulations, and governmental policies, I agree to keep secret, and not to disclose to others nor make any personal use of whatsoever, either during my service on said committee or at any time thereafter, any of such confidential information and to hold any such documents and/or information, regardless of form or nature, in the strictest of confidence.
I understand that any violation of this confidentiality commitment will subject me to disciplinary action, up to and including removal from this committee and/or termination of employment. I further understand that the duty to maintain the information in confidence imposed hereunder shall survive my resignation or termination from this committee and/or my termination of employment with this organization for any reason.
Signature/Date _________________________________
Printed name/Title ______________________________
Witness signature/Date ___________________________