While serving as the chief ethics and compliance officer at Cushman & Wakefield, Maria D'Avanzo spent some years reporting directly to the general counsel and other periods reporting to the CEO.

D'Avanzo said she felt she was more effective when reporting to the global real estate giant’s chief executive.

She emphasized the positive optics of reporting to the CEO for the compliance function as a key reason she preferred that type of working arrangement.

For example, one chief executive D'Avanzo reported to requested that she attend Cushman & Wakefield’s biweekly global business meetings in New York. 

One time before starting the meeting, the CEO even asked why a key business leader was sitting in D'Avanzo’s typical seat and had the two switch places.

Gestures like that help set the tone that the company’s business leaders were to treat D'Avanzo and the compliance team with respect, she said.

This, in turn, led to some high-level personnel being more responsive and cooperative with her than they had been in the past.

“I had the autonomy, the empowerment and the authority that I needed to do my job,” D'Avanzo said in an interview.

D'Avanzo, who previously held compliance leadership roles at AIG Asset Management and Starwood Capital Group, left Cushman & Wakefield in 2022 after 10 years with the company.

She now serves as chief evangelist officer at Traliant, which provides online compliance training.

D'Avanzo recently discussed with Legal Dive the other key reasons she believes compliance chiefs should report to CEOs. She also provided examples of how CCOs reporting to GCs can still achieve success.

Investigations

D'Avanzo said a reporting line to the CEO is helpful for compliance chiefs when carrying out investigations. 

She highlighted that GCs are typically considered part of management and provide advice to senior executives, so they may not be as supportive of the need for compliance and ethics teams to thoroughly investigate company leaders.

“As the chief compliance officer, you're not part of management. You're independent of management,” D'Avanzo said. “It makes for a conflicted relationship sometimes.”

In her experience, CEOs are more likely to understand that while an investigation of an executive may be disruptive in the short term, it will help protect against possible issues for the organization that could linger.

“The CEO is more inclined to say, ‘Just a second here. We need to worry about the bigger picture. I need to put that fire out so that there's not a long-term impact on the organization as a whole,’” D'Avanzo said. “It’s just a different lens.”

Budget discussions

D'Avanzo said reporting directly to the CEO on budgeting matters also served her well as a compliance chief.

For example, she could make a direct pitch for new software without having the request filtered through the general counsel, who may have tech needs of their own that trump compliance tools.

“There weren't all these layers, which allowed me to frame the message the way that I want to frame it and not have some spin put on it by the GC with perhaps a different agenda or a different view on its value,” D'Avanzo said. “Having that direct access is really beneficial from that perspective.”

Partnering with GCs

While D'Avanzo preferred reporting to the CEO as a compliance chief, she said she found ways to partner successfully with GCs whom she reported to during her career.

One example she shared took place after Cushman & Wakefield was purchased by a consortium led by private equity giant TPG.

D'Avanzo worked closely with the company’s general counsel to ensure all the merged entities understood the policies that applied to them regarding topics such as anti-bribery and anti-corruption; gifts and entertainment; and economic sanctions. 

This collaboration with the legal chief included traveling to different offices, including in China, to outline the policy changes.

“The two of us coming together as partners made it easier for the local folks to accept these new rules and controls,” D'Avanzo said. “Had I gone in on my own and not had such strong and visible support from the GC, I think it would have been a much different outcome.”

She also said frequent and transparent communication is key for compliance leaders who want to maintain strong relationships with their organizations’ general counsel.

“For a chief compliance officer who feels like maybe they don't have that smooth relationship, my advice would be just be a bit more proactive and ask for that communication,” D'Avanzo said.