DOJ Evaluation of Corporate Compliance Programs
If you think Good Tone or Conduct from the Top means you have an ethical environment, guess again! Some of your people are up to
Lack of separation of the CHIEF COMPLIANCE OFFICER (CCO) and the GENERAL COUNSEL (GC) has been cited as a cause of numerous corporate mishaps or failures. In fact, separation is now the norm in Health Care organizations. In spite of numerous recommendations to separate the two functions, there is general agreement that the roles are closely related, and frequent collaboration is required.