Odee Ltd., a listed company has appointed two independent directors. As part of its familiarization policy it provides key updates and background about the company to the newly appointed directors. The directors have req

Any corporate compliance management framework encompasses the various steps relating to Compliance Identification, Compliance Ownership, Compliance Awareness, Compliance Reporting and Periodical Compliance MIS. Under various business structures, actual process of compiling the information under various laws vary from company to company and is dependent on various factors such as number of units and scale of operations, size of company, number of business activities etc. A brief process of the Corporate Compliance Reporting (CCR)mechanism is as under- Functional heads for reporting of various laws have to be identified. For example- the Company Secretary would be the functional head for reporting of Company Law, Listing Regulations and Commercial Laws. Similarly, the head of the personnel department can report the compliances of labour and industrial laws and fiscal law compliance would be the domain of head of the finance/accounts departments. Each of the functional heads may collect and classify the relevant information from the various units/locations pertaining to their department and consolidate them in the form of a report. The report shall carry an affirmation from the functional heads that the said report has been prepared based on the inputs received from the various units/ offices and then list out the specific compliances/non-compliances, as already circulated to the functional heads. Each of the functional heads should forward their respective compliance reports to the Company Secretary/Managing Director. The Company Secretary would then brief the Managing Director and with suitable inputs from the Company Secretary, the Managing Director would consolidate and present, under his signature, a comprehensive CCR to the board for its information, advice and noting. The whole process of CCR is contingent on the creation and implementation of comprehensive legal Management Information System (MIS). In the process of the Compliance Reporting, the status of compliances or non-compliances, if any, should be communicated to the concerned functional head. Reporting of non-compliances ensures that appropriate corrective action can be timely taken by the responsible person.