The Compliance Officer’s Role
The Compliance Officer has three main responsibilities:- To receive complaints related to EDC’s CSR policies and initiatives and assist EDC in dealing with complaints and, where appropriate, take steps to promote settlement of these complaints, including promoting dialogue or recommending dispute resolution.
- To provide advice to EDC regarding best in class CSR practices.
- To recommend, when required, a compliance audit, which will be conducted by internal and/or external professionals.The Compliance Officer will oversee and monitor these audits.
The Compliance Officer also has responsibilities with respect to internal disclosure of wrongdoing. Policy and associated processes and procedures are currently under development.
Encouraging Dialogue
One of the resolution techniques is for the Compliance Officer to act as an independent broker between parties, so that a mutually satisfactory resolution can be found. This requires an intimate knowledge of EDC’s policies and procedures so that adherence or non-adherence to corporate social responsibility policies can be assessed.
Advisory Role
In this case, the Compliance Officer helps to identify and correct potential problems while striving to maintain a balance of impartiality and fairness. Consequently, it is incumbent upon the Officer to closely monitor corporate activities and policy initiatives so that issues can be identified and viable alternatives recommended.
Conducting a Compliance Audit
One way to investigate a complaint is conducting a compliance audit to determine if EDC is complying with its policies, procedures and guidelines. The audit would be overseen and monitored by the Compliance Officer.
In all cases, the major focus of the audit will be to review compliance. If the audit reveals flaws, these will be brought to the attention of EDC and recommendations on how to make improvements will be made. The Compliance Officer will report to the Audit Committee on these recommendations.
The report may contain recommendations on corrective action, as well as procedural matters.
What Happens to those Recommendations?
Like all ombudsman-like roles, the recommendations made by the Compliance Officer are not binding on EDC. However, it should be noted that these recommendations would be captured in a compliance audit and reasons for not following those recommendations would be sought as part of the audit process. In creating this position, EDC understood that recommendations must be taken seriously and, where possible, acted upon.
