Abstract
It is tough to be a compliance officer. You are expected to bring a detached and objective perspective to evaluating your organization's compliance and ethics program, which can mean letting leadership know of weaknesses and areas for improvement. You must monitor risks and reports from the hotline, which may make you the first person in the organization to sound the alarm for misconduct. And you participate in investigating and imposing discipline for wrongdoing, which may have you asking difficult questions and delivering unwelcome news. If an organization's leaders are inclined to shoot the messenger, you will be in the crosshairs.
The compliance officer's precarious position has led some to advocate for protection from retaliation.' One way to do so is to require the hiring and termination of the compliance officer be with the approval of, or after consultation with, a specified committee of the board of directors. Protection can also come in the form of an employment contract that sets a specific contract term and limits termination to good cause shown.