--- title: Who Leads Compliance - Top or Bottom? A Perspective on ISO 19600 description: Who Leads Compliance - Top or Bottom? A Perspective on ISO 19600 image: https://go.adherent.com/hubfs/Imported_Blog_Media/Blog-who-needs-compliance2.jpg --- [![](https://www.complianceandrisks.com/wp-content/themes/compliancerisk/inc/img/general/compliancelogo.svg)](https://www.complianceandrisks.com/) - Products Products - - [C2P](https://www.complianceandrisks.com/c2p-compliance-knowledge-management-platform/) - [Regulations Management](https://www.complianceandrisks.com/solutions/conquering-the-regulatory-avalanche/) - [Standards Management](https://www.complianceandrisks.com/solutions/standards/) - [Requirements Management](https://www.complianceandrisks.com/solutions/heres-the-regulation-whats-next/) - [Regulatory Topics](https://www.complianceandrisks.com/solutions/regulated-areas/) - [WFSGI Compliant Labelling Requirements Database](https://www.complianceandrisks.com/WFSGI/) - Services Services - [Market Access Service](https://www.complianceandrisks.com/solutions/grow-in-new-markets/) - [Regulatory Process Consulting](https://www.complianceandrisks.com/solutions/best-practices-in-compliance-processes/) - [Environmental, Health & Safety (EH&S)](https://www.complianceandrisks.com/solutions/ehs-and-your-legal-registers/) - [Managed Services](https://www.complianceandrisks.com/solutions/solutions-for-every-day/) - [Training and Systems Implementation](https://www.complianceandrisks.com/solutions/training-and-systems-implementation/) - [Ask Our Experts](https://www.complianceandrisks.com/solutions/your-compliance-question) - Resources News & Resources - [Blog](https://blog.complianceandrisks.com/news-resources?__hstc=67571022.c37393069837d66fdddfdab74b5ad3c6.1593078357468.1593078357468.1593078357468.1&__hssc=67571022.1.1593078357469&__hsfp=693435645) - [Commentary & Analysis](https://blog.complianceandrisks.com/commentary-analysis?__hstc=67571022.c37393069837d66fdddfdab74b5ad3c6.1593078357468.1593078357468.1593078357468.1&__hssc=67571022.1.1593078357469&__hsfp=693435645) - [COVID-19](https://www.complianceandrisks.com/covid-19/) - [Webinars](https://www.complianceandrisks.com/webinars/) - [White Papers & eBooks](https://www.complianceandrisks.com/whitepapers/) - [About](https://www.complianceandrisks.com/about/) Compliance & Risks - [About Us](https://www.complianceandrisks.com/about/) - [Industries](https://www.complianceandrisks.com/compliance-requirements-industries/) - [History](https://www.complianceandrisks.com/compliance-and-risks-history/) - [Careers](https://www.complianceandrisks.com/compliance-risks-careers/) - [Knowledge Partners](https://www.complianceandrisks.com/knowledge-partners/) - [Partners & Affiliates](https://www.complianceandrisks.com/becoming-a-compliance-risks-partner/) - [Get in touch](https://www.complianceandrisks.com/contact/) COVID-19 Regulatory Developments [Find Out More](https://www.complianceandrisks.com/covid-19/) - [Book a demo](https://www.complianceandrisks.com/book-a-demo/) - [Eng](https://complianceandrisks.com) - [日本語](http://complianceandrisks.jp/) ![](https://www.complianceandrisks.com/wp-content/themes/compliancerisk/inc/img/general/burger.svg) Search for: # Who Leads Compliance - Top or Bottom? A Perspective on ISO 19600 --- ##### 07 August 2015 [![Compliance management](https://go.adherent.com/hs-fs/hubfs/Imported_Blog_Media/Blog-who-needs-compliance2.jpg?width=285&height=273&name=Blog-who-needs-compliance2.jpg)](https://go.adherent.com/hubfs/Imported_Blog_Media/Blog-who-needs-compliance2.jpg)Getting buy-in from senior management is always a challenge when it comes to driving initiatives in an organization. In compliance, there is always a danger that the strategy will be mainly ‘hope’ based. In other words; hope nothing goes wrong, hope that if it does, it won’t cause too much disruption or damage. **ISO 19600 (*Compliance Management Systems - Guidelines*)** was only released at the end of 2014 and describes the essential elements of a compliance management system (CMS). Before laying down what a CMS should look like, the standard first sets the scene - What is the context of the organization? What are the internal and external influences that should be taken into account? The first recommendation is to take a structured approach to identify the compliance obligations of the company’s activities, products and services and the risks associated with them. The standard has moved away from the concept of ‘top management’ and goes for the term ‘leadership’ instead. This is wise as leadership is not only to be found in top management. **Get Focused** Drawing up a ‘**compliance policy**’ for your organization will serve to focus minds - What are we seeking to comply with, and to what extent? Where does responsibility lie? This is all underpinned with commitments: - Commitment to meet requirements, - Commitment to continuously improve the management of compliance. **Day To Day** The standard goes on to describe, in a manner similar to other management standards such as  ISO 9001, the day to day activities and functions required to make compliance a part of daily operations. Planning, support, training, communication and awareness all feature. Management and control activities such as planning, monitoring, collection and control of information are included. These will normally form part of any quality management system, so there is no rocket science here (unless of course you are involved in building rockets!). **Measure It** Audit and management reviews are not something always associated with compliance management, particularly those outside of heavily regulated sectors such as pharma/medical, financial or aerospace sectors. ISO 19600 specifies however that these should form part of any good CMS. How else will you know what is happening? **Benefits** One of the main benefits of this standard may be for those struggling with day-to-day compliance issues, who are perhaps under-resourced and under-appreciated. This is not a certifiable standard in the same manner as say ISO 9001 and ISO 14001. Despite this, in laying out a guide to best practice, ISO 19600 provides a means for those on the coal-face to make their case. It can help draw the attention and backing of those in charge of corporate strategy & budgets. It requires that those people take a stated position in relation to compliance, and therefore serves to put accountability where it belongs - with the decision makers. Reference to this standard can serve to validate any initiatives or improvements that are being made. Those wishing to lead compliance can use this standard to bolster their case, be they at the top, or nearer the bottom. Check out our recent [**Regulatory Process Health Check Report**](http://www.complianceandrisks.com/regulatory-process-consulting-survey-results/) and find out how your industry rates for compliance management. ### Written by [Karl Dowling](https://go.adherent.com/commentary-analysis-old/author/karl-dowling) - - - - ## Featured Posts --- ![Stacey Bowers to Present at ICPHSO 2022 Annual Meeting & Training Symposium](https://go.adherent.com/hubfs/icphso%202022%20(1).png) [Stacey Bowers to Present at ICPHSO 2022 Annual Meeting & Training Symposium](https://go.adherent.com/news-resources/stacey-bowers-to-present-at-icphso-2022-annual-meeting-training-symposium) 26 January 2022 ![Regulating Explosive Atmospheres in the Workplace](https://go.adherent.com/hubfs/Regulating%20Explosive%20Atmospheres%20in%20the%20Workplace.png) [Regulating Explosive Atmospheres in the Workplace](https://go.adherent.com/news-resources/regulating-explosive-atmospheres-in-the-workplace) 25 January 2022 ![What's Trending in Product Compliance?](https://go.adherent.com/hubfs/Trending%20Jan%2022.png) [What's Trending in Product Compliance?](https://go.adherent.com/news-resources/whats-trending-in-compliance-jan-22) 24 January 2022 #### Ireland Office   Unit 9 Eastgate Avenue Eastgate Business Park Little Island Cork Ireland +353 (0)21 435 1990 [info@complianceandrisks.com](mailto:info@complianceandrisks.com) #### US Offices   New York 50 Fountain Plaza Suite 1400 Buffalo NY 14202 +1 716 939 1951   California P.O.Box 309 8712 Marysville Road Oregon House, CA 95962 – 0309 +1 530 216 4455 [![Compliance Logo](https://go.adherent.com/hubfs/Compliance_and_Risks_January2018/Images/compliancelogo.svg)](http://www.complianceandrisks.com/) #### Information - [Solutions](https://www.complianceandrisks.com/c2p-platform/) - [Industries](https://www.complianceandrisks.com/industry-solutions/) - [News & Resources](https://www.complianceandrisks.com/resources/) - [About Us](https://www.complianceandrisks.com/about-us/) - [Get in touch](https://www.complianceandrisks.com/contact/) - [About Us](http://www.complianceandrisks.com/about/) - [Get in touch](http://www.complianceandrisks.com/contact/) [![Compliance Logo](https://go.adherent.com/hubfs/Compliance_and_Risks_January2018/Images/compliancelogo.svg)](http://www.complianceandrisks.com/) © 2021 Compliance and Risks Ltd. | [Privacy Policy](http://www.complianceandrisks.com/privacy-policy/)