Not even one-third of Indian companies have a full-time chief compliance officer (CCO), show a survey by Deloitte. While 58 per cent of the surveyed companies at the global level has a full-time officer, in India, only 26 per cent have one. About, 62 per cent of the Indian companies have a designated CCO, but a majority of them have an additional responsibility, according to the Compliance Trends Survey Report.
The survey added top compliance officers generally have the right reporting structure in their company to maintain their independence. For India, 48 per cent of CCOs report to the CEO, whereas 22 per cent report to the board. Globally, only 36 per cent of CCOs report to CEOs, while 21 per cent go to the board.
Globally, 364 companies were considered for this survey, out of which 37 were from India. The survey says 17 per cent Indian respondents held the title of CCO, chief ethics officer, or chief ethics and compliance officer; six per cent held some other C-level title (chief risk officer, chief audit executive); 20 per cent held a variety of titles at the vice-president level.
The rest of the Indian respondents held a range of other titles - director of business conduct, director of anti-corruption audit, deputy compliance officer, business unit compliance officer, etc.
Of the 37 respondents, the single largest industry group represented was consumer & industrial products at 19 per cent. Next were technology, media and telecommunications and financial services industry at 14 and 11 per cent, respectively. The survey report said the sudden increase in the regulatory enforcement in India has catapulted compliance risk on top of the board, management and audit committee agenda. Additionally, it observed that the regulatory regime in India continues to be complex requiring regular interactions with multiple regulators.
“With the increased transparency in terms of board level compliance reporting, there is still a long way to go to integrate compliance as a strategic partner in business,” the report said. According to the survey, 78 per cent Indian organisations perform an enterprise-wide compliance risk assessment with 43 per cent of them doing it on an annual basis. Additionally, only 14 per cent Indian organisations outsource or co-source their employee and ethics hotline as compared to 39 per cent global organisations. As many as 24 per cent organisations do not outsource any of their compliance activities.
Approximately 92 per cent of the Indian respondents mentioned ‘code of conduct’ as the topmost area of responsibility of the compliance function. Globally, the compliance training was considered as the top responsibility.
The report said 57 per cent of Indian organisations measure the effectiveness of their compliance programmes. The most common metrics CCOs use to gauge their compliance effectiveness are internally focused: internal audits, analysis of self-assessment results, feedback from employee ethics survey, analysis of hotline calls, etc. About 81 per cent respondents were confident about the metrics they were tracking. Correspondingly, 16 per cent were not confident that their information technology systems captured and reported all compliance data necessary to get a good sense of effectiveness.