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Adam - I have used a corporate policy for this purpose.  It sets out many of the details of the compliance and ethics program.  Ideally a program starts with a board of directors' resolution that delegates authority to the chief ethics and compliance officer (CECO) and provides the basis for the program. Starting with a resolution is better than starting with a charter or policy because the resolution comes from the very top of the company and therefore binds everyone, including the senior execs.  The policy, which would be driven by the CECO acting on the authority received from the board, covers who does what and how the program will be implemented.  I have generally covered implementation of all the USSGs elements in such a policy.

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Joe Murphy CCEP
Of Counsel CSLG; Co-Founder Sr Advisor Integrity Interactive
Ethikos
HaddonfieldNJ
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Show Original Message -------------------------------------------
Original Message:
Sent: 07-27-2010 00:59
From: Adam Turteltaub
Subject: Compliance Program Charter

This message has been cross posted to the following eGroups: Chief C & E Officer Health Care Network and Chief Compliance Ethics Officer Network .
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I recently heard that some compliance programs have or are developing a charter.

If your program has one, could you share more about it?  What is its purpose?  What does it state?  And so forth.

Thanks,
Adam

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Adam Turteltaub CCEP, CHC
SCCE/HCCA
VP of Membership Development
Encino CA
United States
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