Should you have a conflict-of-interest subject matter expert on your C&E team?
As the compliance and ethics (C&E) field develops so does the need to acquire/maintain relevant subject matter expertise for key areas such as corruption, competition law, privacy, anti-harassment/discrimination, trade or government business, among many others. Should companies have subject matter experts (SMEs) for conflict of interest (COIs)? In my view, not all programs need to have this sort of position. But those with relatively high COI risks – both in terms of the likelihood and impact of a violation, as well as challenges in deploying effective compliance measures – – should consider establishing one. The role is not likely to require the full-time attention of the appointed employee, i.e., it can be an additional responsibility for an individual already in the C&E (or law) department. Note too that the role should be documented and reinforced by inclusion in the individual’s ...