A chief compliance officer must be able to demonstrate to management and the board that the company’s compliance dollars are providing a solid return on investment. Meanwhile, if the company becomes embroiled in an investigation, the CCO must also be able to demonstrate to the government that the program is effective. At the Society of Corporate Compliance and Ethics’ 2014 Compliance and Ethics Institute, Michael Ward, a former Deputy General Counsel and Vice President, Compliance Systems and Investigations for Cisco Systems and former prosecutor, discussed the metrics the CCO should use to measure the effectiveness of a compliance program; strategies for communicating the process; and the results to the relevant audiences. See also “Measuring the Efficacy of Ethics and Compliance Programs
” (Jun. 11, 2014).