When personal computers first came out, they called the underlying software an “operating system” and the first big improvement to that operating system was called “version 2.0.” When society decided we need a systematic approach to preventing, finding, and fixing ethical and regulatory problems, they called it a “compliance and ethics program” and named the person in charge a “compliance and ethics officer.” Naming new versions of something has a purpose: it helps those who are behind to know they are behind.
It’s been about 20 years since we first started using the terms compliance program and compliance officer. About a year ago I first started seeing the term “Compliance 2.0” used by Donna Boehme. She used it to describe organizations that had an independent compliance officer. Michael Scher used the term on the FCPA Blog to describe the Society of Corporate Compliance and Ethic’s annual conference. He used the term Compliance 2.0 to describe an advancement in the understanding of the role of a compliance officer and the function of a compliance program.
Donna and Michael have captured, in a name, the culmination of a lot of hard work by our profession. As a young profession, we are plagued by a lack of understanding of the definition of a compliance officer. We are plagued by people who want to take compliance programs in a direction they should not go. And it’s hard to describe the problem without a name. Through certification, a Compliance Professional’s Manual, social media, 75 annual compliance conferences, etc., the 15,000 members of SCCE/HCCA have reached another level—and naming it something will help.
The name Compliance 2.0 helps those who are struggling to describe advanced compliance programs to others. We want everyone’s compliance program to be effective, and the job description of every compliance officer to be up-to-date. Maybe a little advancement in the nomenclature will help.
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