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There continues to be controversy about whether a company’s general counsel (GC) should also be the CECO,
especially at large companies. Putting aside
the question of whether this is a good idea,
however, I want to pose a different question
for companies that claim their GC is also the
CECO: Could you prove it?
Does this sound like a silly question?
Remember that the CECO is supposed to
be someone with authority and a degree
of independence. The CECO needs to be
positioned to get things done, and should
be visible to employees. The CECO runs
an extremely important operation whose
function is to prevent and detect misconduct
throughout the company. So if you plan to
tell prosecutors and regulators you have a
CECO and it is the GC, can you answer these
1. When the promotion or hiring of your GC
was announced, did the announcement
state that the person was also the CECO?
(I often read notices where the position
is announced as general counsel, VP
and corporate secretary. But CECO isn’t
important enough to mention?).
2. Is the CECO role in the GC’s written
3. Does the GC’s annual evaluation or
assessment cover the compliance program?
4. Is the CECO title on the GC’s
5. Does the GC have any training in the
Compliance and Ethics field?
6. Has the GC ever attended any
compliance & ethics professional
institute, conference, or best
7. Is the GC a Certified Compliance &
8. Does the GC know what the Code
of Ethics for Compliance and Ethics
Professionals is? Does the GC
9. Does the GC have any experience in
compliance and ethics programs?
Remember, when it comes to dealing with
the government, the burden of proof is on
you to establish that you have an effective
program. It could be tough to prove that, if
you cannot actually prove that the person you
state is your CECO really is one. ✵
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By Joseph E. Murphy, JD, CCEP, CCEP-I, Compliance Strategists
Your general counsel is your CECO?