Corporate Governance, Business Ethics, and Global ... implications with regard to corporate governance, business ethics, F and organizational roles and responsibilities. Corporate

22 March/April 2003 ABA Bank Compliance

compliance management

difficult challenges in protecting theirreputations. To meet these challenges,they continually seek to improve theway they conduct their business and tomanage their risks ever more effec-tively. Increasingly, it is recognized thatcorporate governance, ethics, and com-pliance practices are crucial guardiansof a firm’s reputation and integrity.

New challenges for the boardand senior management

With continuing globalization of the fi-nancial markets — accelerated by tech-nology, dramatic industry consolidation,and intensifying competition — regula-tors have reached the conclusion thatcertain issues need to be addressed onan international basis in order to protectthe safety and stability of the financialsystem. Corporate governance andbusiness conduct are high on the list.

Globally, regulators, investors, and otherstakeholders increasingly hold the viewthat the business conduct and compli-ance function is a critical element of anorganization’s corporate governancestructure. Corporate governance is notjust about committee structures, stockoptions, and voting rights — it implies acomprehensive and consistent corpo-rate commitment to integrity evident inits core values, leadership, culture, andbusiness ethics.

The Basel Committee on Banking Su-pervision, International Organizationof Securities Commissions (IOSCO),and the International Association ofInsurance Supervisors (IAIS) have allreleased standards emphasizing man-agement’s responsibility to manage itsbusiness effectively. However, it ismore than this. Regulators want man-agement to demonstrate that it can

by Miles Everson, CharlesIlako, and Carlo di Florio

inancial services institutions arechallenged as never before by fail-ures of corporate governance andbusiness conduct. Daily media cov-erage of financial institution com-plicity in the corporate failures

plaguing Wall Street — along with otherpublic concerns over money launder-ing, conflicts of interest, improper initialpublic offering allocations, and preda-tory lending, to name just a few — hasheightened the scrutiny these institu-tions face from regulators. Reforms arereminiscent of those that followed theGreat Depression, and there is a prolif-eration of proposals intended to restoretrust, integrity, and responsibility in thefinancial services industry. Outside theUnited States, some major financial ser-vices institutions have run afoul of for-eign regulations and found themselvessanctioned — sometimes severely.

Regulatory sanctions are bad; they costtime and money. The real damage,though, is to the firm’s reputation, andpotentially to that of the industry. Intoday’s global financial markets, finan-cial services institutions face ever more

This article looks at the links between corporate governance, business

ethics, and compliance management. It assesses the current state of

play and some of the leading practices in these areas. It puts forward

some suggestions for designing an effective compliance function, and

the implications with regard to corporate governance, business ethics,

and organizational roles and responsibilities. F

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ABA Bank Compliance March/April 2003 23



and practices to demonstrate meaning-ful commitment to business integrity.

Similarly, European regulators are nowalso strongly advocating the establish-ment of a global compliance function tosupport, coordinate, and monitor com-pliance activities at the business line,geographical, and legal-entity level. In agrowing number of European countries,there are now explicit regulatory require-ments covering these areas. For in-stance, global compliance coordinationis necessitated by new requirementsflowing from global efforts to combatcorruption, money laundering, and ter-rorist financing.

In effect, there is an interesting and sig-nificant development occurring in Eu-rope. There are clear signs of convergencein the way European regulators arethinking, as evidenced not least by thework of the Committee of European Se-curities Regulators (CESR). The CESR re-cently issued standards for the harmoni-zation of conduct of business rules inEurope, including a requirement to es-tablish an independent compliancefunction. CESR members (the 15 mem-ber states of the European Union, plusNorway and Iceland) have made a bind-ing commitment to either introducethese standards in their national juris-dictions (where they have the power todo so) or work to persuade legislatorsthat such changes are necessary.

Current state of play

Compliance functions have their longesthistory in the United States, with muchof the relevant legislation dating fromthe 1930s and 1940s. The regulatoryrequirements for compliance functionshave expanded, at times gradually, andat other times, expansion has come in

light of recent events, a further reviewwas recently completed by a workinggroup chaired by Daniel Bouton, presi-dent of Société Générale, resulting inrecommendations that are leading tofairly wide-reaching changes.

In the United States the recent waveof Wall Street scandals has resulted inwidespread reform. Sarbanes-Oxleylegislation is accompanied by activecriminal and civil proceedings againstfinancial services institutions, new rulemaking by the Securities and ExchangeCommission and Government Account-ing Office, revised listing and analyststandards (NYSE, NASD, AMEX, NAS-DAQ), new business practices for securi-ties firms and rating agencies, and ahost of new expectations and standardsvoiced by institutional investors, profes-sional associations, and other stakehold-ers. Independence and disclosure arethe prominent themes.

These reforms place new requirementson boards of directors, board commit-tees, senior management, and keyethics and compliance functions. Forboards, independence is required forthe audit, nominating, and compensa-tion committees. Boards are required tomeet without management present, in“executive sessions.” There are also anumber of new compliance, code ofconduct, and whistleblower protectionrequirements. The NYSE requires corpo-rate governance and business ethicsguidelines to be available on the institu-tion’s Web site. This, of course, requiresthat firms support such representationswith substantive compliance processes

manage its business risks effectivelyand conduct its business ethically,across multiple jurisdictions, entities,products, and activities.

The issue of corporate governance hasbeen the subject of much debate in Eu-rope over the past few years. At the levelof the European Union, the “Report ofthe High Level Group of Company LawExperts on a Modern Regulatory Frame-work for Company Law in Europe,” is-sued in November 2002, has tabled aseries of recommendations aimed at ra-tionalizing EU company law to reinforcecorporate governance.

In the United Kingdom there have beena number of corporate governance–related studies since the milestone Cad-bury Report in 1992, culminating in the“Combined Code: Principles of GoodGovernance and Code of Best Practice”from the Committee on Corporate Gov-ernance. The Financial Services Author-ity (FSA) uses this code as a backdrop toits approach to senior manager respon-sibilities, to which a section of the FSA’snew handbook is dedicated. As a result,the link between corporate governanceand compliance becomes explicit. Weexpect that a similar clear link will bemade in other European countriesshortly, if it is not already.

In Germany a blue ribbon committeeproduced the country’s first corporategovernance code a year ago. In France,an extensive set of corporate gover-nance rules was introduced in France asa result of the Viénot reports of July1995 and July 1999. Nevertheless, in

Recently compliance requirements have spread into previously

unregulated sectors of the financial services industry as a

result of money laundering and terrorist financing.


Table 1: FSG criteria for an effectivecompliance program

Criterion

1. Compliance standards and procedures

2. High-level officer

3. Due care in delegating authority

4. Effective communication

5. Monitoring/auditing/reporting

6. Consistent discipline

7. Process modification

Indicative high-level self-assessment questions

• Do comprehensive and consistent compliance policies and procedures

exist throughout the enterprise?

• Is the code of conduct a proactive and complete summary statement of

the organization's positions on ethics and compliance?

• Have specific responsibilities for compliance been assigned to senior man-

agement and the board?

• How are the reporting relationships for compliance structured to ensure

independence and effectiveness?

• Are there appropriate and established limitations to signatory and decision-

making power?

• Is effective due diligence conducted on agents, consultants, and other

business partners?

• Does the organization conduct detailed performance monitoring for disci-

plinary action?

• Does the company conduct periodic compliance and awareness training

for all employees?

• Is training targeted for particular job responsibilities in compliance-sensitive

areas?

• Is there a clear organizational chain of command for employees to approach

for help with questions or reporting questions or concerns?

• Does the company have a confidential means for employees to report con-

cerns or ask questions about ethical issues anonymously (e.g., a helpline or

confidential mailbox)?

• Has the company demonstrated willingness to reinforce compliance by con-

sistently disciplining offenders, regardless of their position in the organization?

• Is ethical behavior included as part of individual performance evaluations

and as a predictor for successful advancement?

• Does the company maintain records of compliance materials it has gener-

ated and revised, certification materials, and case handling records that

may be needed in the event of future issues/investigations?

• Does the company proactively monitor emerging issues and key risk areas

to respond to real or potential problems and determine what remedial

actions might be necessary?

United States, theevolution of thecompliance functionover the past decadehas been rapid. Thisevolution startedfrom two differentpoints of origin. Inthe United King-dom, for example,the requirement forcompliance func-tions grew out ofmarket failures andfocused primarily on

conduct of business rules. In other coun-tries, where bank finance still remainsthe most prevalent form of financing,the need for a bank compliance functiondeveloped from the regulatory require-ment for “adequate administrative andaccounting organizations and systemsof internal control.” Now there is grow-ing consensus across Europe that thecompliance function should ensure regu-latory compliance in all areas of the fi-nancial services institutions’ operations.Starting from two different points oforigin, the concepts are now convergingquickly.

Globally, similar operational models arebeing adopted for the compliance func-tion. The most prevalent model in theUnited States, and now in Europe, is astand-alone compliance function. Thisreflects widespread recognition that thecompliance function is an independentstaff function supporting the governingand managing bodies that are ultimatelyresponsible for compliance. To a greaterextent than the internal audit function,the compliance function also needs tobe close to business units on a day-to-day basis in order to spot potential com-pliance risks at the operational level andhelp resolving them.



concentrated bursts, as a reaction toscandals caused by rogue individualsor financial institutions, as a responseto international events (e.g., the USAPATRIOT Act), or from a general updat-ing of the U.S. financial system (e.g., theGramm-Leach-Bliley Act).

More recently, compliance requirementshave spread into previously unregulatedsectors of the financial services industry(e.g., hedge funds, private equity funds,and venture capital firms) as a result ofconcerns about money laundering andterrorist financing.

Since 1991, compliance programs inthe United States have been anchored,generally, in the framework establishedby the U.S. Federal Sentencing Guide-lines (FSG) for Organizations. The FSGprovides seven core criteria for manag-ing a company’s ethics and compliancerisks (see Table 1, page 25).

Some comparisons can be drawn withEurope. PricewaterhouseCoopers has re-cently undertaken a study looking at thecurrent state of play and future trendsfor compliance functions in Europe.1

While compliance functions do not havethe same history in Europe as in the

A number of international banking andsecurities groups have established acentralized compliance function over-laying a network of local complianceofficers who are based in front-linebusiness units — thus addressing theneed to be independent while stayingclose to business units. This approachresponds well to business units’ needsbut can cause difficulties dealing withlocal regulatory requirements that cen-ter on legal entities. Other groups, there-fore, have chosen to coordinate com-pliance activities both at the businessline and country/legal-entity level. Theseapproaches create potential difficultiesin terms of both independence andconsistency that warrant careful man-agement attention. To operate effec-tively, a compliance function needs:

• a clearly defined structure and unam-biguous reporting lines that preserveindependence and demonstratesenior-level commitment;

• adequate financial and human re-sources — meaning, where possible,no direct reliance on business unitsfor the necessary budgets and con-flict-free human resources policieswith regard to recruitment, remuner-ation, and performance assessments;

• a charter setting out roles and re-sponsibilities and the scope of activi-ties (covering in particular the inter-action with other departments suchas internal audit and legal);

• a realistic apportionment of responsi-bilities set forth in documented andmonitored annual plans;

• periodic independent verification toassess program effectiveness andongoing improvement.

Senior Executive Officer/Board

Functional relationship Reporting lines

Country Head/CEO

Business LineHeads

Business LineCompliance Officers

(Country/Regional Level)

Global Headof Compliance

Country/RegionalHead of Compliance


At the group level, care is needed toensure consistent coverage — acrossbusiness lines and geographies — withnational requirements. One size doesnot necessarily fit all.

Leading practices

In the United States today many finan-cial services institutions are looking togo beyond basic adherence to the FSG interms of their compliance functions.Leading ethics and compliance pro-grams seek not only to establish soundgovernance practices but also to embedcompliance with such practices into cor-porate culture. Similarly, in Europe, it isincreasingly recognized that the compli-ance function serves four key objectives:

• demonstrating compliance with rele-vant regulations;

• identifying, addressing, and resolvingregulatory failures;

• managing the cost of compliance;and

• embedding compliance within theorganization overall.

Currently, compliance functions in Eu-rope often cope well with the first twobut have yet to fully address the secondtwo. The goal, nevertheless, is a corpo-rate culture that both encourages andrewards compliance.

Embedding compliance

PwC has undertaken a considerableamount of work helping clients developthe essentials of a values-based compli-ance supporting culture. Through this,it has become clear that companies thathave successfully evolved into leading

Table 2: Best Practices for Achieving aCompliance-Supporting Culture

• Board and senior management commitment to ethics and compliance.

• Global compliance function supported by a cross-functional management

compliance committee.

• Clearly defined objectives, success measures, and project management

capabilities.

• Effective upstream and downstream communication.

• Consistent accountability at all levels.

• Integration of compliance into individual performance measurement and

reward structures.

• Values-based approach to ethics and compliance.

• Knowledge management to facilitate learning and leverage successes and

failures.

• Continuous improvement based on objective measurements.

• Effective use of compliance-enabling technology to enhance program man-

agement, communication, monitoring, and reporting

• Constructive engagement of internal and external stakeholders.

• Leveraging compliance process improvement to enable business process

improvement.

• Systematic measurement of compliance program effectiveness, including man-

aging and mitigating costs.

• Development of early warning systems and effective dispute resolution

processes.

• Redefinition of the ethics and compliance program to encompass frameworks

that provide support for corporate social responsibility (CSR) programs and triple

bottom line reporting of the organization’s economic, environmental, and social

performance.



practices in this area share several com-mon traits that enable forward thinking,continuous improvement, and effectivechange management.

PwC has developed a broad-based ap-proach to support clients in adoptingcompanywide mandates to create acompliance-supporting cultures,3 called“total compliance continuum.” This ap-proach focuses on cultivating an ongoingcommitment to compliance throughoutthe organization and enables financialservices institutions to build effective pro-grams on three fronts:

1. Through board and management“tone at the top.” Business ethics ad-dress how a company cultivates a cul-ture of doing the right thing andintegrating core values, such as re-sponsibility and trust, into the waybusiness is conducted across the orga-nization. Both the board and top man-agement need a strong, unified visionconcerning the compliance program’spurpose. Management is responsiblefor planning and implementing an effective compliance program, whilethe board oversees management toensure that implementation occurs andcorporate responsibilities are met on anongoing basis.

2. Through a values-driven code of con-duct. Values serve as a beacon for acompany’s decision-making processesand determine how a company behavesin uncertain times. The company’sethics and values regarding complianceneed to be “lived” and embodied in aclearly written code of conduct that ismeaningfully communicated to all em-ployees and associated third parties.This code should not only express man-agement’s values but also identify andreflect the values of major stakeholders.

Table 3: Compliance Roles and Responsibilities

Enterprise Level

• Provide centralized compliance coordination and oversight with the support of

the compliance committee.

• Set and communicate vision, objectives, and enterprise policies.

• Develop annual global compliance plans that link global and local objectives

and goals.

• Ensure that compliance requirements encompass a full range of enterprise

issues and objectives.

• Ensure that consistent policies are adopted across functions.

• Establish an umbrella plan for training and education.

• Help the enterprise achieve quality of service and product by participating in

the new product/business line development process and assessing the compli-

ance impact on existing business lines.

• Provide an ombudsman function to answer questions and address reported

issues.

• Create a structure and protocol governing investigations.

• Provide tools and technologies for compliance assessment and implementation.

• Define key measurements to be used as a basis for program assessment and

continuous improvement.

• Monitor enterprise and functional program performance.

• Create a structure and protocol to coordinate investigations and disciplinary

actions.

• Provide coordinated knowledge management and facilitate sharing of best

practices/lessons learned.

• Leverage the compliance framework for early issue identification and resolution.

• Identifying emerging issues and facilitate integration into business conduct

framework.

• Report to management and the board on program performance, and develop

effective compliance dashboard key performance indicators.

• Identify opportunities to leverage compliance process improvement to enable

business process improvement.

Functional Support of Enterprise Program

• Implementation of enterprisewide framework in a manner that is consistent with

and supports functional needs.

• Leverage enterprise tools and technologies to the extent practicable.

• Provide training and communication that are integrated into the enterprise

umbrella framework.

• Monitor and measure program performance using established metrics.

• Identify emerging risks and develop proposed control frameworks.

• Report on program effectiveness (including incident management).

• Identify best practices and lessons learned for knowledge management and

leverage at an enterprise level for continuous improvement.

that subsequently should be incorpo-rated in the compliance program.

Key success factors

The “good” compliance officer hascome a long way from the “You can’tdo that” school to one in which he orshe is more than prepared to give ad-vice and assistance to all areas of thebusiness. This has been described byone compliance officer as “the art ofthe possible” — helping the firm un-derstand what can be done from a reg-ulatory viewpoint, coaching on bestpractice, passing on lessons learnedoutside the firm (and even outside theindustry), acting as a sounding board,and in general showing managementthat getting the customer’s experienceright from a commercially driven view-point can also meet key governance,compliance, and regulatory require-ments. To achieve this balance in thecompliance department, leadership,


Examples of Key Performance Indicators • Board/senior management oversight practices and charters

• Code of conduct awareness and signatures

• Ethical culture surveys of employee opinions

• Helpline awareness and call resolution

• Compliance process effectiveness ratings

• Training records and effectiveness

• Adequacy of program documentation

• Awareness of newsletters and articles

• Risk management and early detection

• Consistency of enforcement

• Management response to issues raised

• Management response to audit findings

• Helpline trends

• Degree of ethics message integration

• Percentage of questions versus allegations

• Investigation results

• Exception reporting (e.g., know your customer checks, fact-finding quality,

market transactions)

• New account openings and business volumes by product and customer type

• Number of sales observations conducted

• Appraisals and observations outstanding

3. Through effective integration in busi-ness processes. Integration with busi-ness processes includes developingclear policies and procedures; commu-nicating to, and training, employeesabout the code of conduct and relatedpractices; monitoring progress; report-ing to management and the board;fine-tuning strategies; and communi-cating the company’s successful perfor-mance to key stakeholders. Integrationensures that the compliance andethics program becomes operationaland effective.

When designing a compliance function,an institution must consider bothfunctional roles and compliance re-sponsibilities, together with enablingtechnologies and emerging standards

Compliance Effectiveness Cycle

EnterpriseCompliance

Workflow


vision, creativity, proactivity, and out-standing communication skills arenecessary.

A key issue is staffing. The staffing of ei-ther the head office compliance unit orthe regional/local office compliance unit(or individual) will depend upon numer-ous factors, including the following:

• overall staffing of the financial ser-vices firm;

• the types of customers served by theinstitution (retail and/or institutional);

• the products offered to the customerbase (e.g., commercial and/or con-sumer lending, money markets, capitalmarkets, whether primary offeringsand/or secondary trading);

• the geographic reach of the company(local, regional, national, or interna-tional); and

• the various distribution channelsused by the institution (e.g., sales

forces, third-party marketers, bricksand mortar offices, and cyberspace).

The mixture of the above factors, plusothers (for example, the local gover-nance and regulatory environment ateach international office, its specificrules and complexities, and the applica-tion of technology in the complianceprocess) will affect the level of compli-ance staff required, as well as the com-petencies and experiences of the staffutilized, in order to enforce and monitorthe applicable standards, rules, and reg-ulations the financial services institutionmust follow.

While the chief compliance officer ofan organization will usually have abroad compliance background, theexact experience of the unit’s staff andits applicability to various front-officedepartments and products has becomean increasingly important factor. Justhaving a compliance unit is not enough;the staff must have the requisite com-petencies and specialties in order tomaster compliance risk and understand

the ways in which it manifests itself atthe group, entity, business unit, product,and transaction levels.

Performance monitoring

Compliance functions and programsshould be independently reviewed onan annual basis, by internal audit andpossibly by external parties to assesseffectiveness. Across the financial ser-vices industry, compliance functionshave developed a wide range of compli-ance dashboards to help them assessprogram effectiveness and monitor thecompliance risk profile of the businesson an ongoing basis.3

Although these dashboards vary interms of their content, sophistication,and presentation style, they have a com-mon feature: feedback to managementand the board regarding a number ofprescribed key performance indicators(KPIs) — a fundamental of good corpo-rate governance.

From work in this area, PwC haslearned a number of lessons relating tothe use and effectiveness of compliancemetrics and dashboards:

The first lesson is that the most effec-tive dashboards do not concentratesolely on the purely compliance-relatedKPIs (such as persistency), but also in-clude some reference to the broaderbusiness performance of the organiza-tion, such as sales performance, andtraining and competence statistics.This provides management with amuch broader view of the organiza-tion’s compliance performance, andallows for more immediate identifica-tion of the underlying issues that may be causing the poor complianceperformance.

Functional Roles and Compliance Responsibilities



The second lesson is that the dashboardshould be devised in such a way that itenables the cross-referral of KPIs andmakes for easy identification of correla-tions. An obvious example might bethe possible correlation between theaverage span of control and the num-ber of sales observations outstanding.However, we have seen instances wherecorrelations have been identified be-tween two KPIs that would not at firstglance seem connected but which, oninvestigation and over time, haveproved to be linked and of significance.The dashboard must show the KPIs astrends and not just as one-off figures.What is of interest to management isthe ways in which the KPIs changeover time and not just the absolutefigures.

Finally, there is a feature of compliancedashboards that we have not yet seen,but which we expect to see developedand have discussed with clients. Hith-erto, dashboards have traditionallybeen historical; they report what hashappened in the recent past. If dash-boards contain the trend and correla-tion analysis capabilities describedabove, we see no reason why they can-not become a tool for use in planningthe future. By extrapolating trends, andby using as predictive tools the correla-tions already identified, it should, inour view, be possible to use the dash-board as a tool for scenario planningand impact assessment. This wouldenable the compliance officer to moreeffectively fulfill his or her role as astrategic adviser: The dashboard wouldgive him or her the means to say tomanagement “if you do this, that willhappen”; he or she would be able toshow the cause-and-effect linkages be-tween the various factors involved inrunning a regulated firm.

Compliance-enabling technologies

Compliance departments in U.S. finan-cial services institutions use a varietyof additional tools — such as robustrisk management frameworks, earlyissue identification and resolution pro-cesses, and balanced scorecards —that drive ethics and compliance per-formance throughout the organization.

Knowledge management is improving,generally, in compliance departmentswith the use of internal bulletin boards,intranets, and knowledge databases.The more sophisticated tools allowfirms to track issues and breaches andkeep affected parties informed of theirresolution. Specifically, the use of datamining systems to enhance monitoringfor anti–money laundering purposeshas acquired increased importance afterthe events of September 11. Such sys-tems are already widely used in theUnited States and their use is increasingin Europe. These systems have provedto be highly effective for comparingactual customer transactions against acustomer’s profile. They have enormouspotential for monitoring compliancewith conduct of business requirementsthat impose a duty of care on a financialservices institution.

A host of new compliance-enablingtechnologies are emerging that provideenterprisewide compliance solutions,as opposed to more traditional solu-tions that address specific issues, suchas money laundering. These new en-terprise solutions provide knowledgemanagement for all the compliancepolicies and procedures of an organiza-tion; facilitate the compliance manage-ment processes; allow the firm tocommunicate, train, track, test, andverify awareness and understanding

among employees; and pipe into trans-action systems using rules-based en-gines to identify and elevate risks andtrigger workflows.

In effect, compliance departments mustretool and reskill themselves with newframeworks and methodologies for riskassessment and they must obtain en-hanced management information tomeasure and monitor compliance. Theywill need to make better use of newtechnology if they are to report on anddemonstrate compliance to senior man-agement, boards of directors, regulators,investors, and other key stakeholders.In making these changes, they mustensure that they are properly alignedwith their firms’ business strategies,operational business, and the expecta-tions of major stakeholders.

The Value

Corporate governance, business ethics,and effective compliance managementare increasingly critical to financial ser-vices institutions. Globalization, technol-ogy, and product complexity presentchallenges across the board. For the financial services industry, however,these are compounded by regulators’concerns about business conduct,money laundering, conflicts of interest,predatory lending, improper marketingand many other business integrity is-sues. To safeguard one’s reputation, thebest way forward is to embed ethics andcompliance into all systems, processes,and procedures — basically into the cul-ture of the organization.

However, embedding ethics and com-pliance into corporate culture could bea major challenge. The roles and re-sponsibilities of the board and seniormanagement, in addition to those of


about the authorsthe compliance function, need to beextremely clear. The organization andstructure of the compliance function,reporting lines and review processes,the required skills and competencies ofcompliance personnel, the use of en-abling technologies, and, not least, thekey performance indicators that will beused to measure the effectiveness of thecompliance function all need to be con-sidered carefully. But this is only part ofthe picture. Embedding compliance willrequire cultural change — the impact ofwhich will differ from organization toorganization. The key challenges formanagement will be, first, to design,communicate, and operationalize effec-tive governance, values, and compli-ance throughout the organization. Intoday’s environment, a firm’s successor failure may well rest on the mannerin which it effectively and holisticallyaddresses corporate responsibility. ❖


Have a question or comment?Use the postage-paid reply card pro-vided in this issue or leave a message at (202) 663-5075.

1. “Regulatory Compliance: Adding Value. A Review ofFuture Trends,” October 2002.

2. “Corporate Governance - Compliance at the Core.”3. “Best Practice and Delivering Value — The Future

for Compliance.”

Miles Everson is a partner with PricewaterhouseCoopers in New York, fo-

cusing on operational effectiveness in the financial services industry.

Charles Ilako is a partner with PricewaterhouseCoopers in London and

leads the financial services regulatory advisory practice in Europe, the Middle

East, and Africa. Carlo di Florio is a director with PricewaterhouseCoopers

in New York, focusing on corporate governance, business ethics, and compli-

ance management solutions. The authors can be reached at (646) 471-4000.

This article draws on extensive PricewaterhouseCoopers’ thought leadership in

the area of corporate governance, business ethics and compliance man-

agement. Special appreciation goes to Bob Bench and Roger Coffin in the

United States, Andrew Podd in the United Kingdom, Peter PT Li in Hong Kong,

and Wendy Reed in Belgium.

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Corporate Governance, Business Ethics, and Global ... implications with regard to corporate governance, business ethics, F and organizational roles and responsibilities. Corporate