Viveka Strangert

Question 1

7 elements of an effective compliance program.

Answer 1

1. Policy, standards and procedures.
2. The tone-at-the-top, including dedicated CCO.
3. Fit- and proper process.
4. Training and communication.
5. Monitoring, auditing and whistleblowing.
6. Aligned remuneration and
   consequences in the event of noncompliance.
7. Structured learning process.

Question 2

What is compliance according to Viveka?

Answer 2

Compliance is what happens between the rules and behavior. Is not necessarily so that you always follow all the rules

Question 3

How can compliance officer remain independent?

Answer 3

1. Not performing any operational tasks that CCO monitors and controls
2. Organisationally separated from what CCO monitors and controls
3. Not subordinated to a person with responsibility for managing
   activities that CCO monitors and controls
4. Remuneration that does not risk to compromise CCO’s objectivity