Interim Chief Compliance and Conduct Officer — Exposure Renewal

Three routes for every exposure

Every compliance and conduct exposure in an insurer can be dealt with in one of three ways. You can treat it, by changing the product, process, control or behaviour that creates it. You can transfer it, to a reinsurer, a partner, a distributor's contract or an outsourcer, provided you remember that conduct responsibility rarely moves as neatly as the contract suggests. Or you can exit it, by withdrawing a product, a channel or a relationship. The interim officer's task is to make that choice exposure by exposure, and to defend each choice to a board.

The calls are rarely clean. Treatment is attractive because it keeps revenue, but it depends on platforms and people actually changing, and remediation that cannot be delivered is only a promise. Transfer looks tidy on a risk register, yet a customer harmed through a partner usually remains the insurer's problem in a supervisor's eyes. Exit is decisive and often unpopular, and it lands on colleagues who built what is being closed. The officer weighs each route, says which way it goes and answers for the outcome.

The authority to do that is real. Reporting to the Board of Directors, you will set how exposure decisions are made and the point up to which market compliance heads may decide on their own. You will fix the standard of proof behind how capital is deployed, capacity committed and controls tested across markets, and rule on whether each inherited commitment continues or ends. You will stop proposals that relocate cost or risk to nobody in particular, and decline investment whose case overlooks take-up, the other work it leans on, or failure. You will approve the leadership arrangements and how issues rise, settling disagreements between directors and product or distribution heads before resources move.

From a map of exposures to decisions made

The first ninety days produce a map of the principal compliance and conduct exposures, each carrying a proposed route and an accountable person. By around month nine those decisions should be agreed and in motion, and conduct exceptions should reach the board by a single route rather than several. By month 12 every exposure decision should be completed, or passed on with its evidence to the executive who will carry it, and conduct oversight should be part of what the board routinely receives.

A compliance leader who has owned the outcome

You have run compliance, conduct or risk for a business with at least $290 million in revenue and 400 people, present in six or more countries. Your knowledge of insurance comes from calls that carried your name, among them a commitment lacking support that you halted before it caused damage, and you have kept your footing where underwriting, claims and capital platforms had to keep running through a change of leadership. Experience of professionalisation, joint ventures and succession will be weighed; joint ventures in particular show whether you understand where conduct accountability really sits when two parties share a customer. Directors expect risk judgement at level 4, alongside level 3 in regulatory engagement, assurance testing and the setting of risk appetite. You have also withheld money from a case that could not say who would use the change or what it could cost, and then rebuilt the compliance capacity the work needed.

Four conversations before a conduct mandate

Stage one, in week one, is a confidential screen-to-screen discussion with the Board of Directors. The Board Chair follows in week three, in a session built around real work rather than questions. By week five you will be in the room with a panel of senior leaders drawn from every function, and the directors as a whole meet you in the seventh week. Our response comes in writing, two working days after each stage at the latest.