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Compliance Leadership Model


The CLM is based on the widely-used standards-- ISO 14001: Environmental Management Systems and ISO 19600: Compliance Management Systems, as well as the U.S. Federal Sentencing Guidelines. The levels in the model represent programs with:

    • increasing capability,
    • strengthened organizational structure,
    • increased focus on risk reduction,
    • greater integration of sustainability, and optimization of environmental performance. 
Every retailer has different compliance obligations and regulatory risk and therefore, not all retailers will need or want to progress though the model for every dimension. However, all compliance programs should include Essential Level elements--click here for a summaryUsers can refer to the CLM Resource Library for corresponding tools and guidance resources for each dimension. Click on the headers below for a description of each level. 

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Level 1: Essential -

Organization has the basic elements of a compliance program needed to meet regulatory requirements. Top management has overall responsibility for compliance programs and delegates responsibility for facility-level compliance to facility managers, resulting in site-specific implementation.

Level 2: Structured -

Regulatory programs are coordinated and consistently applied across different sites. Responsibility for compliance is centralized with dedicated experts, resulting in more efficient systems.

Level 3: Optimized -

Standardized, systematic compliance activities (e.g., training, auditing, reporting and management review) are integrated into existing business processes and applied across all compliance programs. Programs analyze data to improve performance and reduce compliance risk and environmental impacts.

Level 4: Proactive -

Environmental compliance is integrated into the business strategy of the enterprise, including the organizational culture. Programs proactively identify new and emerging environmental issues to minimize compliance risks and enhance sustainability. Life cycle thinking is used to engage value chain partners and capitalize on business value from environmental compliance activities.

Last Update: 6/14/2019 1:14:15 PM