In the recent Corporate Integrity Agreement (CIA) between Pfizer and the Office of the Inspector General of the Department of Health and Human Services, Pfizer agreed that its chief compliance officer will now report directly to the CEO; will neither be nor be subordinate to the general counsel or CFO; and will make periodic reports to the Audit Committee of the board.

Most compliance professionals agree that the appropriate positioning of the compliance and ethics (C&E) officer within an organization is critical to the success of a program. But, does it really harm a compliance and ethics program when the general counsel is also the head of Compliance and Ethics? Or is Legal the appropriate department for a function that has the primary purpose of preventing legal violations? And how important is it that the compliance and ethics officer report directly to the CEO?

Where the C&E officer should report is not an easy question for many organizations to answer, and most companies would likely argue that the most effective positioning varies between organizations. In order to gather valuable benchmarking data for its members, the SCCE recently disseminated a nine-question survey regarding C&E officer positioning.

The survey was answered by a total of 560 respondents. The majority of respondents were from public or privately-held organizations (26% from publicly-held, and 24% from privately-held). The survey also drew a large number of respondents from non-profit institutions (36%), educational institutions (8%) and government entities (6%).

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