Speaker: Michael Bromwich, Managing Principal, The Bromwich Group
Today, at the New York Regional Compliance & Ethics Conference, we had the exciting and informative treat of participating in a Q&A with Michael Bromwich, moderated by Jeff Kaplan.
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Michael Bromwich founded The Bromwich Group in 2012, which offers monitoring, crisis management, strategic advisory, and public affairs services, in addition to more specialized services relating to offshore energy and law enforcement. Mr. Bromwich’s career has spanned more than 30 years, during which he has served as a federal prosecutor, a special prosecutor, an inspector general, and prior to forming the Bromwich Group, was selected by President Obama and Interior Secretary Ken Salazar to reform the regulation and oversight of offshore drilling in the wake of the Deepwater Horizon accident and spill.
The Q&A session with Mr. Bromwich was insightful, engaging, and covered a whole host of issues that could arise when addressing risk and the C-suite. For me, after participating in the lively discussion, there were three impactful takeaways.
The first takeaway involves a best practice when working with, and appointing, members of a Board. The key here is ensuring that there is an individual on the Board with a compliance and ethics background, which would be the gold standard. Not only will this individual serve symbolically, by showing that the organization values and takes compliance and ethics issues seriously, but also practically, by bringing the knowledge and experience of a seasoned compliance and ethics professional to the table.
Second, a gold standard compliance program will address issues across the entire organization. This includes issues that can arise all the way from entry level employees to the C-suite. Ensuring that all individual roles are accounted for in the program will ensure that the compliance program is robust and complete.
Finally, someone asked a question about whistleblowers, especially when this entails blowing the whistle on a C-suite individual. This discussion really got me thinking about what a hard decision that would be, and about Compliance 2.0, which describes the importance of the compliance officer’s independence. It would still be a difficult situation to address as an individual within the organization, but allowing the CCO to have independence might ease the fear of job security in such a situation.
This session was truly informative, and brought up many challenging issues that the compliance profession faces when addressing risk in the C-suite. If you ever have the opportunity to listen to a session with Mr. Bromwich, you will not be disappointed.