The Role of the Chief Legal Officer

1. 2013 Global Ethics Summit The Role of the Chief Legal Officer March 5, 2013

2. Changing Role of the CLO • The role of the Chief Legal Officer (CLO) has evolved over the past 5 years, and now is increasingly independent of the chief compliance officer function. There is still debate as to the value of separating the two positions. • Regardless of the CLO‘s official compliance responsibilities, he or she is still spending time addressing compliance related issues. • Changes in CLO focus includes more attention paid to issues in Latin America and Asia, such as anti-corruption efforts, anti-boycott efforts, and labor issues in the supply chain.

3. Creating a Culture • The CLO has a responsibility to set the Tone from the Top alongside other senior executives of a company. Messaging must come from the CLO around ethics and the organization‘s values, and stress the importance of company policies addressing specific risks. • Examples of how CLOs are creating an effective Tone from the Top include hosting semi-annual roundtables which can be hosted in different regions around the world, as well as regular written communications to employees around the world.

4. Risk Assessments • CLOs increasingly see value in risk assessments – whether the risk assessments are developed in-house or through a credible third party – as an important tool for developing a compliance and ethics program and culture. • The CLO should play a role in the risk assessment process, such as working to identify organization‘s key risks and to develop/implement effective tools for mitigating identified risks.