Read “7 risks and compliance threats facing in-house counsel” for more about this topic. 

Until February, Bradley Siciliano was general counsel of Sharp Electronics, the U.S. subsidiary of Osaka, Japan-based Sharp Corp., where he led the implementation of the company’s first ethics and compliance program.

“Companies like Sharp, where you have a couple thousand employees, aren’t that large in terms of revenue and population, and dedicating people specifically to compliance and going out and hiring a compliance specialist is a really big investment,” says Siciliano, now a shareholder at Littler Mendelson.

A common path for small or midsize companies such as Sharp is to identify the internal resources capable of filling that role. At Sharp, that entailed putting together a committee of five existing employees with skills and background in financial accounting, investigations, internal audit and communications to address the various elements of the company’s compliance needs. They underwent training in compliance issues, studied what other companies were doing and used that education to customize a program that would work for Sharp. As the company’s operations and needs changed, the committee modified the program as needed. As the domestic subsidiary of a foreign company, the committee also worked to blend its compliance program with its parent company’s and to identify legal and cultural aspects of the programs that worked in Japan but not the U.S. and vice versa.

For small and midsize companies, Siciliano says, using the company’s existing personnel to address compliance is a near-universal approach.

“Almost every single compliance person I met at a recent conference I attended had been doing something else—legal, HR, accounting—and fell into compliance by accident or by need,” Siciliano says.