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Telling the Board what it needs to know Regarding Compliance – The Pfizer Experience (Originalwiedergabe des Blogartikels) . Wichtige Lektion: Compliance Abteilung und Rechtsabteilung getrennt halten.

An article in the July Issue of Compliance Week Magazine, entitled “Telling Your Board What it Needs to Hear”, author Arielle Bikard discusses the views of Pfizer Inc’s Chief Compliance Officer (CCO), Douglas Lankler, on how he keeps the Pfizer Board of Directors up to date on compliance issues. There are many articles which focus on the information that a Board of Directors may want to receive and this is one of the few articles which focuses on the issues from the perspective of the CCO.

Reporting Structure. Due to a recent compliance enforcement action, Pfizer was forced to separate its compliance function from its legal function and Lankler began to report directly to the Board. This has led to a tripartite level of reporting at the Board level. There is a monthly meeting of the Audit Committee, to which he reports to, by telephone and bi-monthly in person meetings, to which Lankler also reports. There is also a special Board level committee dedicated to regulatory and compliance issues, to which Lankler began reporting to in June. Lankler also submits an annual report to the full Board.

What is Measured and How is it Presented

Lankler noted that the Pfizer Board is “very concerned about how the company is measuring improvements in the compliance function.” To provide this information, Lankler measures the results of inspections during internal monitoring and auditing. He provided the example of whether a country assessed received a “generally satisfactory” rating as opposed to the lessor rating of ‘satisfactory”. He is also measured on “how much bad stuff I prevent from happening.” To determine this metric, Lankler brings in “external environmental considerations” which look at what is happening in the industry and what his and Pfizer’s peers may be facing from the compliance perspective.

Lankler believes that the key to reporting is to provide sufficient information presented in a manner which puts the emphasis on what is important. To achieve the latter, he prepares a tracking chart and uses a red, yellow and green dot next to each line of information. He believes that this allows the conversation with the Board to be directed “in a way that makes sense.” If he adds to or subtracts from the tracking chart, “the change and its cause are highlighted in a memo to the Board.”

The annual report which is submitted to the Board comes in at 30 pages or so. In it, Lankler sets out four different areas which he beli…