You have been appointed as Company Secretary of a newly incorporated public limited company, which is engaged in providing logistic services across India. The company has come out with a public issue and its shares are l

Being a Company Secretary i.e. 'Compliance Manager/ Officer' of the company, I would ensure that the company is in total compliance with all regulatory provisions. I would ensure that all statutory and non-statutory disclosures are made to shareholders and other stakeholders in true letter and spirit. I would draft a Corporate Compliance Management Policy and put up before the board of directors for their approval and implementation. The policy would contain following aspects- Background and business strategy of the company: This will include the brief background of the company, area of operation, competition prevailing from the peer companies and SWOT analysis of the company, marketing strategies to be adopted, use of technology in providing better services to the customers. Identification of applicable laws: This will include identifying the applicable laws, application of control measures to mitigate the risk, generation of reports for identifying the non-compliances, reminder before the due date for compliances and having internal control on compliances. Individual responsibilities on compliances to be clearly defined: Responsibility with respect to compliances would be clearly defined in the compliance management programme, which will enable the compliance officer to co-ordinate with the respective officials in respect of deviations if any. Evaluation: Compliance management system would have a proper evaluation methodology through questionnaires for departmental heads etc. at regular intervals. Bridging the gap between compliance in letter and compliance in letter and spirit: The compliance management system would be made in such a manner that the compliance is made in letter and spirit. Updation: Updation of compliance management programme is very essential as and when there is any change in any of the applicable law.