The Society of Corporate Compliance and Ethics surveyed its members in 2009. According to a summary of the findings by John Soriano in Compliance Week, the survey found a plurality (45%) of chief compliance officers reported directly to the CEO. Only 17 percent of the respondents reported to the chief…
This blog has commented before on the reporting lines of chief compliance officers (CCO’s) (See my post of Jan. 20, 2009: reporting lines of compliance function with 11 references.). It had not occurred to me that government agencies might take a position. According to an article in Compliance Week by…
General counsel can find themselves with all kinds of functions reporting to them. An unusual example appears at Polaris Industries a $1.6 billion manufacturer of snowmobiles and other products. The law department of Polaris has four lawyers and paralegals in her department. Aside from that, according to a profile of…
Although it is easy to list differences between companies that have publicly-traded shares and privately held companies, how those differences play out in legal department responsibilities, structure and budget so far remains unknown. In the fullness of time and benchmark participation, all will be revealed (See my post of Dec.…
A supplement in the ACC Docket, June 2010 after 32, uses terminology from Coca-Cola’s legal group in Europe. They describe their business unit lawyers as “operational lawyers” and their specialty lawyers as “functional lawyers.” Other legal departments apply different labels. What we call the two kinds of lawyers in legal…
Corp. Counsel, May 2010 at 25, mentions in passing that Mitchell Zamoff is the “co-general counsel of United-Health Group.” Before, I have wondered how twin GCs parcel out decision-making and avoid competition (See my post of June 16, 2007: co-general counsel at Citigroup and the former Computer Associates; and April…
Jerry Okarma is the vice president, secretary and general counsel of Johnson Controls. He is a member of the company’s executive operating team, and oversees all legal and compliance activities of the company. In addition, and to the point of this speculative post, Okarma is responsible for shareholder services, enterprise…
Corp. Counsel, March 2010 at 77-79, makes several points about the litigation group at Ford Motor. (1) The group employs the most lawyers in the department. That should sadden everyone except those in the litigation group, because no company sees litigation as a core competency (except patent trolls) and litigation…
In Corp. Counsel, March 2010 at A4, a partner at Anderson Kill discusses claims investigations by in-house counsel and two privileges. “For the work-product doctrine to apply, the investigation must be outside of standard claims handling process. For attorney-client privilege to apply, the attorney must provide legal advice and not…
It is no easy matter to create in the minds of departmental lawyers a collective sense that they are pulling the oars together, especially when they are all over the world and come from many different legal backgrounds. Bits and pieces of techniques to do so had appeared here and…