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Using organizational alliances to meet compliance objectives

Tosin Umukoro (tosin.umukoro@stryker.com) is the Director of Compliance for Stryker UK & Ireland.

According to the United States Department of Justice’s Evaluation of Corporate Compliance Programs, effective implementation of a compliance program requires those charged with the program’s day-to-day oversight to act with adequate authority and stature.[1] Sufficient resources, seniority within the organization, and autonomy from management are all factors that prosecutors take into consideration when investigating an organization to ultimately determine whether to bring charges, negotiate a plea bargain, or come to other agreements.

While it is increasingly accepted that a compliance team operating independently can best serve a corporation’s interests, it is also well known that planning the structure of the compliance function is not an off-the-shelf task.[2] Careful consideration of an organization’s unique features and control requirements all affect the optimal compliance structure. A large company, for instance, with several places of business, hundreds of employees, and multiple business units is likely to require specific compliance roles and compliance professionals to be aligned appropriately within the business. Specialist compliance professionals afford business units a dedicated compliance resource, with more knowledge of each unit’s activities and the inherent risks, which can be advantageous for mitigation activities. Smaller organizations, however, can also effectively achieve compliance objectives with one central team.

For most organizations—no matter the size—when compliance objectives are part of the overall mission, they become mutual goals among departments, thereby enabling the formation of alliances between compliance and other functions. These alliances have a synergistic effect on the reach and impact of the compliance program by engaging key stakeholders, accessing specialist skills and capabilities, and/or overcoming the lack of compliance resources. Therefore, it is vital that compliance professionals be strategic about their alliances and allow the functions they partner with to work where they’ll bring the most value.[3]

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