Interim Chief Compliance and Conduct Officer — Renewal

A compliance leader who asks what actually happened

The person we want has, at some point, looked at a compliance dashboard full of green attestations and asked to see what actually happened. Compliance or conduct functions you have led served businesses of no less than $685 million in revenue and 3,200 people, operating in eight or more countries, and you have stopped at least one unsupported commitment before its consequences reached the business. Before approving that an exception continue, you have identified who bears its economic cost. ESG transition, professionalisation and succession are the experiences we will explore with you; ESG in particular, because sustainability claims have become a fast-growing source of conduct risk and the evidence behind them is often thin.

Risk judgement is wanted at level 4; risk appetite, assurance testing and regulatory engagement are each wanted at level 3. Assurance testing carries special weight in this seat, since the mandate is to replace completion rates with test results. We also want someone who stays answerable after the board has decided, including for the slow, unglamorous work of closing exceptions one at a time.

Where the centre draws the line

As an interim executive answerable to the Group Chief Executive Officer for 12 months, and holding real authority, the Chief Compliance and Conduct Officer sets which compliance decisions sit with local leadership and which come to the centre. The officer decides the evidence on which spending, capacity and the control environment are judged across markets, reviews every commitment taken on before the appointment and rules on its future, and blocks any proposal that would saddle a market or function with a cost or risk it has not signed up for. Investment cases that are vague about take-up, dependencies or what could go wrong are declined. The officer signs off the compliance leadership team and how concerns travel upward, resolves disagreements with operating leaders while spending is still undecided, and runs the board's calendar for conduct findings, open exceptions and pending calls. In a listed company these decisions may eventually be read by people outside the boardroom, and the officer should write them with that reader in mind.

From policy to proof in twelve months

The first ninety days should bring the Group Chief Executive Officer and the officer to agreement on who decides what in compliance, and on a standard of evidence for assurance that replaces policy completion as the measure of success. Around month nine, conduct and compliance controls should have been tested against that evidence, with each failed test owned by someone and given a date for closure. By month 12, evidence-based assurance should be reaching the board routinely, and conduct oversight should be in a condition that others can carry forward.

Testing the approach with those it affects

The process begins in the first week with the Group Chief Executive Officer, one to one and on video. The third week brings a session with the Regional President on how evidence-based assurance works in operating markets. Week five is in person with executives who lead the separate functions, and the seventh week is with the full board. We aim to respond to each stage in writing inside five working days.