Interim Chief Compliance and Conduct Officer — Recovery

Not a policy-writing exercise

Compliance appointments are sometimes framed as documentation work: refresh the policies, update the training, produce a framework. This one is about decisions. Over 12 months, reporting to the Audit Committee Chair, the Interim Chief Compliance and Conduct Officer will decide which compliance and conduct exposures the organisation treats with stronger controls, which it transfers through insurance, contracts or partners, and which it exits by stopping the activity altogether. Each answer has a cost, and the officer will be expected to state it.

The exposures and the authority

In healthcare and life-science services the exposures are varied: clinical conduct, data protection, anti-bribery in relationships with clinicians and payers, research integrity, and the conduct of third parties who act in the organisation's name. Some can be controlled economically, some are better carried by others, and a few are not worth carrying at all.

The officer carries executive authority. You will design how compliance decisions are made, writing down how far each local head may go alone, and decide what proof a request for capital, capacity or a compliance control must carry in each market in scope. Each commitment gets your ruling on whether it proceeds, waits or stops, and each exposure your ruling to treat, transfer or exit. Plans that let exposure drift to no one in particular are stopped, and investment cases missing adoption, dependencies or the downside are declined. Approval of the leadership structure, and of the route for raising concerns, rests with you, as does settling conflicts between the Audit Committee Chair and operating leaders before any resources are spent.

Six countries of judgement

Working across six or more countries, in organisations with revenue of $945 million or more and a staff of at least 5,600, you have learned to tell necessary local judgement from variation that merely persists. Your experience includes professionalisation, a joint venture and succession. Risk judgement must be at level 4, with assurance testing, regulatory engagement and risk appetite each at level 3.

Baselines of yours have held when an audit committee chair pressed on them and when the clinical and service leaders nearest the work pressed harder. You can name a well-liked commitment you brought to an end, show why, and show what the freed capacity went on to do. You can describe an unresolved gap to an audit committee chair without letting uncertainty postpone the decision. If halting a commitment would need every country head to agree, or you would like influence while someone else carries the 12 months of accountability, this will not suit you.

The register, the decisions and the process

The first ninety days should leave the organisation with an exposure register agreed with the Audit Committee Chair, every compliance and conduct exposure on it assigned to someone who will answer for it. By month nine each material exposure should carry a decision to treat, transfer or exit, with conduct controls tested wherever exposures are retained. By month 12 those decisions should be implemented and conduct standards applied across markets, with the results reported to the audit committee.

The Audit Committee Chair begins the process with you, confidentially and by video, during week one. In week three you work with the Regional President on how exposure decisions would land in operations. By week five you are facing executives from each function in person, and week seven closes with the full board. Five working days is the longest you will wait, after any stage, for our assessment in writing.