2022

ACC CHIEF LEGAL

OFFICERS SURVEY
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TABLE OF
CONTENTS
INTRODUCTION______________________________ 4

KEY FINDINGS_________________________________ 5

SECTION 1:
The Chief Legal Officer’s
Role and Reach__________________________________ 10

SECTION 2:
The Legal Department’s
Value to the Business___________________________ 24

SECTION 3:
The Political and
Regulatory Landscape__________________________ 34

SECTION 4:
The Outlook for the
Legal Department_______________________________ 48

Participant Profile_______________________________ 60

Research Methodology_________________________ 64
INTRODUCTION
The Association of Corporate Counsel (ACC) is pleased to present the results of the 2022 Chief Legal
Officers Survey in partnership with Exterro, the exclusive ACC Alliance Partner for E-Discovery, Data
Privacy and Cybersecurity Compliance. For over 20 years this annual survey has sought to capture
insights from Chief Legal Officers (CLOs) on the evolution of their role and that of the complex
corporate legal department environment. It serves as a cornerstone for the entire in-house community
as to the trends, challenges, and opportunities for the year ahead from the CLO perspective.

This year’s results reveal a rapidly evolving and dynamic corporate legal environment where legal
officers and their departments are playing an even greater role to shape and influence the broader
business. The COVID-19 pandemic, diversity and equity issues, and the sociopolitical environment
worldwide intensified many of the challenges faced by Legal, but it has also brought into focus the
immense value Legal brings to the businesses it serves. As a result, several trends to note include
expected significant transactions (M&A, spin-offs, etc.) have risen to become the number one
upcoming resource challenge, while cybersecurity and data privacy issues continue to pose enormous
legal challenges. CLOs are taking on far more responsibility and oversight, particularly related to
Environmental, Social, and Governance (ESG) issues. The increased responsibility and workload
are leading CLOs to increase hiring across the board this year and they are especially interested in
investing in legal operations to further improve costs and efficiencies for their legal departments. In
this challenging employment environment, CLOs also described a heightened focus on prioritizing the
needs of their employees as they work to fill a particular need for staff who possess strong leadership
and communications skills in addition to their specialized legal knowledge.

It is clear that for legal departments and their organizations to remain competitive, an ability to adapt,
reprioritize, and act decisively are more important than ever. Providing relevant data-driven insights
from member CLOs worldwide on their challenges, priorities, and outlook is critical to ACC’s core
purpose of advancing the interests of the in-house legal profession. This year’s report contains key
insights from 861 participants from organizations spanning 20 industries and 38 countries, from small
legal departments in companies with under US $25 million in annual revenue to large multinational
corporations with revenues larger than US $50 billion. It is one of the largest and most comprehensive
surveys of CLOs on the market.

We want to thank the CLOs who dedicated a few minutes of their valuable time to participate in this
survey. Without your generosity and support, this important study would not be possible. We hope that
you find the survey results interesting and relevant to your role as law department leaders.

Sincerely,

Veta T. Richardson Blake E. Garcia, Ph.D.

President & CEO Senior Director of Business Intelligence
Association of Corporate Counsel Association of Corporate Counsel

4 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY FINDINGS

1 THE CLO CONTINUES TO PLAY A VITAL

ROLE IN THE BUSINESS
The CLO plays a critical role in the company’s leadership. Eighty
percent of CLOs report directly to the CEO, a metric that has
remained stable around this threshold for the last four years.
Furthermore, a solid majority of CLOs always attend board meetings,
meet with other business leaders to discuss operational issues,
and are consulted by other executives on key business decisions.
CLOs dedicate on average more than one-third of their time at work
contributing to strategy development, advising executives on non-
legal issues, and handling board and governance matters, thus
providing value to the business far beyond their legal expertise.

2 INCREASING RESPONSIBILITY IS
BEING PLACED ON CLOs
On top of managing the legal department and providing legal advice,
which represents on average around fifty percent of the job, CLOs
also oversee other critical business functions: 80 percent oversee
compliance, practically half oversee ethics and privacy, and four
in ten handle business risk. Out of 21 different business functions,
more CLOs have direct oversight over 18 of these functions than
they had in 2020. Of particular note, nearly one quarter of CLOs are
now responsible for ESG, up nine percentage points from 2020.

acc.com/surveys | 5
KEY FINDINGS

3 INVESTMENT IN LEGAL OPERATIONS

IS ACCELERATING
Six in ten legal departments have at least one dedicated legal
operations professional, three times higher than in 2015, and this is
the case in more than half of participating departments since 2020.
At least 50 percent of legal departments across all company sizes
have one or more legal operations professionals, and 75 percent
of companies with US $3 billion or more in annual revenue have
dedicated legal operations staff. In addition, 70 percent of CLOs
listed legal operations as the area of focus for their department’s top
strategic initiative.

4 CLOs EXPECT TO HIRE MORE STAFF

THIS YEAR
Across six different types of staff positions, CLOs expect to hire more
personnel in 2022 compared to last year. Forty-five percent anticipate
hiring lawyers and 29 percent expect to hire more paralegals, a
13-point and nine-point increase from 2021, respectively. Participants
list increasing headcount as one of the actions taken to improve
internal client satisfaction with the department’s delivery of legal
services, aimed at shortening delivery times and providing more
coverage and better service. Leadership, communication and
listening, and business management are the most relevant skills that
CLOs expect for lawyers in the legal department to develop.

6 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

5 CYBERSECURITY, COMPLIANCE, AND
DATA PRIVACY REMAIN THE MOST
CRITICAL AREAS FOR THE BUSINESS
Cybersecurity, regulation and compliance, and data privacy remain
the top three issues that CLOs rank as most important for the overall
business, with averages of around eight points on an importance
scale ranging from one to ten. All three areas scored slightly higher
than last year. The high importance given to these three areas aligns
with CLOs’ expectations that industry-specific regulations and
data protection privacy rules will most likely pose the biggest legal
challenges to the business. Sixty-six percent anticipate that industry
regulations will cause the biggest legal challenges this year and
55 percent list data protection rules as a cause for legal concern.
Nevertheless, most CLOs are at least moderately confident that their
organization can consistently defend and respond to cybersecurity
incidents and breaches.

6 HIGHER REGULATORY ENFORCEMENT

WILL LIKELY LEAD TO GREATER
WORKLOAD IN 2022
Sixty percent of participants expect an increase in the volume of
privacy regulatory enforcement in 2022, with CLOs in the insurance
(90 percent), information (89 percent), and accommodation and
food services (85 percent) industries overwhelmingly anticipating
higher pressure from regulators. Two-thirds of participants expect
that the regulatory environment will require organizations to improve
its compliance efforts, and accordingly a majority of CLOs expect
that compliance-related expenses will increase to some extent in
2022. Additionally, 41 percent of CLOs expect to send more work to
law firms this year, the highest percentage observed since 2019 and
seven points higher than last year.

acc.com/surveys | 7
KEY FINDINGS

7 M&A POSES TOP UPCOMING LEGAL

RESOURCE CHALLENGE
Significant corporate transactions (M&A, spin-offs, etc.) will be the
area that requires the most additional departmental resources in
2022, according to 25 percent of CLOs—a four-point increase from last
year. This is followed by compliance with 16 percent and data privacy
with 13 percent. In addition, thirty-nine percent of CLOs say that M&A
issues are most likely to cause the biggest legal challenges for their
organizations. This expectation is particularly pronounced among
CLOs in Europe, Middle East, and Africa (EMEA) and North America.

8 ESG ISSUES CONTINUE TO

GAIN RELEVANCE AND IMPACT
BUSINESS STRATEGY
Four in ten CLOs indicate that ESG issues are forcing companies
to improve their compliance efforts to adapt to new environmental
regulations and satisfy the growing number of investors and
customers that are emphasizing ESG and CSR. One in six
respondents in public organizations reported having received
pressure from investors for taking a stand or refraining from taking a
stand on social and political matters. CLOs are getting more involved
in handling ESG and CSR: 24 percent of CLOs declared that they
oversee these functions as part of the legal department, compared
to just 15 percent of CLOs in 2020.

8 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

9 CONTRACT MANAGEMENT IS TOP TECH
AREA IN WHICH CLOs PLAN TO INVEST
Fifty-five percent of CLOs are either planning on adopting new
technology solutions in the legal department in 2022 or have just
recently added new technologies to improve efficiencies and
streamline processes. Among those who anticipate expanding or
updating the legal department’s technology capabilities, 70 percent
are looking into improving their contract management software,
around one-third intend to invest in document management and
workflow tools, and one-quarter want to acquire new technologies
in collaboration management, matter management, data privacy,
analytics, and eSignature. Technology is deemed essential to
successfully comply with data privacy regulations, with 56 percent
of participants stating that they implemented new technology last
year to assist with this critical task, and CLOs also recommend the
automation and digitalization of legal department processes to
improve internal client satisfaction and streamline operations.

10 CLOs SEE DELIVERING VALUE TO

CUSTOMERS AS THE TOP PRIORITY,
BUT INVESTING IN EMPLOYEES GROWS
IN IMPORTANCE
Half of participating CLOs rank delivering value to customers as
their organization’s top priority in the next five years, an item that
has consistently been the top priority since we started asking in
2020. Maximizing profits is the main corporate goal according to 26
percent of CLOs, but this number is down from 35 percent in 2020.
Conversely, investing in employees has grown by nine points, with
19 percent of CLOs stating that this is what their organization will
primarily focus on in the next five years, compared to just 10 percent
in 2020. This result aligns with the observed tendency of a stronger
focus on ESG and CSR issues that CLOs have also noticed.

acc.com/surveys | 9
SECTION 1

THE CHIEF LEGAL OFFICER’S

ROLE AND REACH

This section explores the organizational structure of the legal department and the
role and reach of general counsel and chief legal officers. It presents key metrics,
including the percentage of CLOs that report directly to the CEO and that have a
reporting line to the company’s board of directors, as well as a general outlook into the
legal department’s current state of affairs.

SECTION HIGHLIGHTS

80% Eight in ten CLOs report directly to the CEO

52%
of CLOs have a
direct reporting line
Over half of participants also assume
the role of corporate secretary 54% to the company’s
board of directors

24%
One in four
Six in ten departments have at least
one legal operations professional 60%
CLOs oversees
environmental, social,

45%
and governance (ESG)
and corporate social of CLOs anticipate hiring more
responsibility (CSR) lawyers in 2022

10 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

As the highest-ranking lawyer in your organization, what title do you hold?
General counsel is the most common title for the highest-ranking lawyer in the legal department. Sixty-six
percent of survey participants indicated their title to be general counsel, the same result observed in 2021.
However, this year’s question allowed respondents to select more than one title, if applicable, which provided
for additional flexibility. As a result, the percentages shown add up to more than 100 percent.

One in five respondents hold the title of chief legal officer, while the other listed options are much less
common: Head of legal (8 percent), director of legal (4 percent), and group general counsel (2 percent).
Seventeen percent of respondents reported another title, up from eight percent last year. These include
additional responsibilities reflected in their titles, such as chief administrative officer, chief compliance officer,
and company secretary. Executive level titles are also common alongside the legal job title, namely executive
or senior vice president.

Head of Legal 8%

Group General Counsel 2%

General
Counsel Chief Legal Officer 21%
66%

Director of Legal 4%

Other 17%

OTHER TITLES USED

•C
 hief Administrative Officer •C
 hief Risk Officer
•C
 hief Compliance Officer •G
 eneral Manager, Legal
•C
 hief Human Resources Officer •V
 ice President, Legal

acc.com/surveys | 11
SECTION 1: THE CHIEF LEGAL OFFICER’S ROLE AND REACH

Do you also hold the title of or

assume the role of corporate/
company secretary? NO
Fifty-four percent hold the title or assume
the role of corporate secretary, while five
YES 42%

percent of participants reported that the 54%

corporate secretary reports directly to
them. These results are largely unchanged
compared to last year’s survey. No, the corporate
secretary reports
directly to me
5%

KEY TREND
Do you report directly to the Chief Executive Officer (CEO) or
highest-ranking executive officer?

PERCENTAGE “YES”

2018 2019 2020 2021 2022

64% 78% 80% 78% 80%

Eighty percent of survey participants responded that they report directly to the chief
executive officer (CEO) in their organization. The trend shows how the value of this
critical metric has become stable across the last four editions of the survey, with
four in five participants reporting to the CLO, a considerable increase from the value
of 64 percent observed in 2018. Across all company sizes, CLOs in organizations
headquartered in North America tend to report directly to the CEO in larger numbers than
those in organizations headquartered in other global regions.

12 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

Participants that do not report directly to the CEO were then asked which other position they report
to. The 2022 results do not differ from those recorded in previous editions of the survey. Almost half
of participants who do not report to the CEO report to the company’s chief financial officer (CFO), 15
percent report to the chief operating officer (COO), and 11 percent report to the chief administrative
officer (CAO). Eight percent report to the chief legal officer of their holding or parent company, and
seven percent report directly to the company’s board of directors. Although it represents a minor
percentage of participants, this number has increased annually since 2020. One in five CLOs in this
group report to yet another individual in their organization, such as the chief compliance officer, the
chief risk officer, or to a company vice president.

To whom do you directly report in your organization? Select all that apply.
Only asked to those who do not report directly to the CEO (n = 175).

CHIEF FINANCIAL OFFICER

47%

CHIEF OPERATING OFFICER

15%

CHIEF ADMINISTRATIVE OFFICER

11%

CHIEF LEGAL OFFICER OF THE

HOLDING OR PARENT COMPANY

OTHER FUNCTIONS AND POSITIONS

8%
•C
 hief Compliance Officer
BOARD OF DIRECTORS
•E
 xecutive Vice President
•C
 hief Human Resources Officer
7% •G
 eneral Manager
OTHER •C
 hief Risk Officer
•P
 resident

21%

2020 2021 2022

acc.com/surveys | 13
SECTION 1: THE CHIEF LEGAL OFFICER’S ROLE AND REACH

KEY COMPARISON
CLOs directly reporting to someone other than the CEO by company revenue
Some variation exists when looking at the results by company size, as shown in the following key
comparison. A majority of respondents in smaller companies (less than US $100M in revenue) that
do not report directly to the CEO report to the chief financial officer, but only 26 percent of those in
larger companies do so.

CLOs in these organizations report to a more diverse field of individuals and functions, with 20 percent
reporting to the chief administrative officer, 17 percent to the CLO of the holding or parent company, and
14 percent to the chief operating officer. The results are similar to those recorded in last year’s survey,
with the main differences observed in the US $500 million to US $2.9 billion revenue range: the 53
percent of participants reporting to the chief financial officer is 20 points higher than last year, and those
reporting directly to the board of directors also increased by 10 points (from just 3 percent in 2021).

REVENUE
LESS THAN $100M $100M TO $499M $500M TO $2.9B $3B OR MORE

Chief financial officer 60% 56% 53% 26%

Chief operating officer 15% 19% 15% 14%

Chief administrative
8% 5% 20% 20%
officer

Chief legal officer

of the holding or 0% 5% 5% 17%
parent company

Board of directors 5% 5% 13% 6%

Other 18% 19% 13% 23%

14 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

Do you have a reporting line
to the board of directors? YES
Half of all participants indicated that they have a reporting NO 52%
line to the organization’s board of directors, 40 percent
40%
responded otherwise, and nine percent of participating
organizations do not have a board of directors. The
distribution is very close to that of the 2021 survey. Do not have a board of directors 9%

Which of the following corporate functions report to you? Select all that apply.
The cybersecurity response and information governance functions were not listed in 2021.

74%
COMPLIANCE 80%

43%
ETHICS 48%

46%
PRIVACY 47%

40%
RISK 40%

26%
GOVERNMENT AFFAIRS 29%

ENVIRONMENTAL, SOCIAL, AND GOVERNANCE (ESG) / 15%

CORPORATE SOCIAL RESPONSIBILITY (CSR) 24%

14%
PUBLIC/CORPORATE AFFAIRS 18%

CYBERSECURITY RESPONSE N/A

16%
CLOs selected which
20%
specific corporate functions
HUMAN RESOURCES 16% report to them from a
ADMINISTRATION 18%
15%
comprehensive list of 21
14%
different business divisions.
REAL ESTATE/CORPORATE FACILITIES 15%
The five most common
ENVIRONMENT, HEALTH AND SAFETY (EHS) 10%
11%
functions reporting to CLOs
8%
remain unchanged since
INTERNAL AUDIT 11%
2021, with compliance (80
INFORMATION GOVERNANCE N/A
10%
percent, up from 74 percent
8%
last year) topping the list
COMMUNICATIONS 9%
by a considerable margin,
INFORMATION SECURITY 9%
9% and followed by ethics
8% (48 percent), privacy (47
PHYSICAL SECURITY 9%
percent), risk (40 percent),
PROCUREMENT 6%
8% and government affairs (29
6% percent). Ethics and privacy
INFORMATION TECHNOLOGY (IT) 5%
swapped places compared
3%
FINANCE 3% to the 2021 results.
3%
SUPPLY CHAIN 3%

19%
OTHER 13% 2021 2022

acc.com/surveys | 15
SECTION 1: THE CHIEF LEGAL OFFICER’S ROLE AND REACH

KEY TREND
Legal department functions that have become more common in the
last two years
Having inquired about which functions report to the CLO starting in 2020, the following
chart shows the five functions that have become more common in the CLO’s portfolio of
responsibilities in the last two years. Environmental, social, and governance (ESG) and corporate
social responsibility (CSR) top the list, with a considerable increase of nine points in the 2020-
2022 period. One in four CLOs oversees ESG/CSR compared to just 15 percent two years ago.
Public and corporate affairs show an increase of five points, followed by compliance and risk
(four percent), and communications (3 percent) closes this top five list.

Environmental, Social, and

Governance (ESG) / Corporate +9%
Social Responsibility (CSR) 15% 24%

Public/corporate affairs +5%

13% 18%

Compliance +4%
76% 80%

Risk +4%
36% 40%

Communications +3%
6% 9%

2020 2022

16 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY COMPARISON
The following key comparison provides the results of the corporate functions that CLOs oversee
if they oversee either of the four most common functions: compliance, ethics, privacy, or risk. The
results shed some light to better understand which functions are most often grouped together
under the CLO’s supervision.

A majority of those who oversee compliance also oversee ethics (55 percent) and privacy (51
percent), and 45 percent oversee risk. Among those who oversee ethics, nine in ten oversee
compliance (ten points larger than the overall survey results) and a majority also oversees privacy
and risk. Similarly, 55 percent of those that oversee privacy also oversee ethics, but only 47 percent
oversee risk. Finally, those overseeing risk have the highest percentages of ethics and privacy
oversight (62 percent and 55 percent, respectively), and 35 percent of them also oversee ESG/CSR.

Percentage of legal departments that oversee each function among

those who…

… oversee Compliance … oversee Ethics

ETHICS 55% COMPLIANCE 90%

PRIVACY 51% PRIVACY 54%

RISK 45% RISK 52%

GOVERNMENT GOVERNMENT
AFFAIRS
32% AFFAIRS
40%

ESG / CSR 25% ESG / CSR 35%

… oversee Privacy … oversee Risk

COMPLIANCE 86% COMPLIANCE 89%

ETHICS 55% ETHICS 62%

RISK 47% PRIVACY 55%

GOVERNMENT
AFFAIRS
35% ESG / CSR 35%
GOVERNMENT
ESG / CSR 27% AFFAIRS
34%

acc.com/surveys | 17
SECTION 1: THE CHIEF LEGAL OFFICER’S ROLE AND REACH

Are there any functions that don’t report to you that you believe should?
Participants were also asked about whether there are any corporate functions that they believe they should
oversee. This bar chart lists the functions that CLOs believe they should oversee based on the percentage of
participants that would like to oversee each function among those who do not currently oversee them. The
inner bars reflect the share of CLOs that would like to oversee each function among those who reported not
overseeing each function, which is represented by the outer bars.

For example, 20 percent of survey participants indicated that compliance does not report to them, but 43 percent
of them believe that it should. Therefore, in relative terms, compliance tops the list because it has the largest
percentage of participants that would like to oversee this function among those who currently do not oversee it.

Although only a minority of participants expressed willingness to oversee each of the listed functions, there are
some interesting changes compared to last year’s results. Risk remains the second function in this list with 17
percent of those who do not currently oversee it wishing to do so (two points less than in 2021), but ESG/CSR is
now the third function that CLOs believe should oversee with 16 percent, compared to just eight percent last year (it
also ranked eight). Government affairs and ethics (16 percent and 15 percent respectively) complete the top five.

COMPLIANCE 43% 20%

RISK 17% 60%

ENVIRONMENTAL, SOCIAL, AND GOVERNANCE (ESG) /
CORPORATE SOCIAL RESPONSIBILITY (CSR)
16% 76%

GOVERNMENT AFFAIRS 16% 71%

ETHICS 15% 52%

PRIVACY 14% 53%

CYBERSECURITY RESPONSE 8% 84%

HUMAN RESOURCES 8% 84%

INTERNAL AUDIT 7% 89%

PUBLIC/CORPORATE AFFAIRS 6% 82%

ENVIRONMENT, HEALTH AND SAFETY (EHS) 5% 89%

PROCUREMENT 5% 92%

INFORMATION GOVERNANCE 4% 90%

COMMUNICATIONS 3% 92%

INFORMATION SECURITY 3% 91%

ADMINISTRATION 2% 85%

PHYSICAL SECURITY 2% 91%

REAL ESTATE/CORPORATE FACILITIES 2% 85%

SUPPLY CHAIN 2% 97%

FINANCE 1% 97%

INFORMATION TECHNOLOGY (IT) 1% 95%

FUNCTION DOES NOT REPORT TO ME (AMONG ALL RESPONDENTS)

FUNCTION SHOULD REPORT TO ME (AMONG THOSE WHO DO NOT OVERSEE EACH FUNCTION)

18 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY TREND
The prevalence of legal operations in the legal department as shown in this time series remains
positive and reflects that a majority of participating legal departments have at least one dedicated
legal operations professional in the staff. Since 2015, when we first tracked this metric, the number
of departments with one or more legal operations professionals has nearly tripled.

Please indicate the number of legal operations staff that are employed
in your legal department in all locations. (Staff that are solely
dedicated to operations – i.e., not doing any legal work):

2015 2016 2017 2018 2019 * 2020 2021 2022

Percentage of
departments 49% 47% 61% 60%
with at least one 43%
54%
legal operations
professional 21%

12.6
Average number 9.5
of legal operations 8.5
professionals in the 8.0
legal department
5.9
5.4 5.2
4.3
3.2
OVERALL
4.5
$1B OR MORE 1.8
LESS THAN $1B
2.2 2.4
1.2
0.8

In terms of the average size of the legal operations team, the overall trend shows a decrease since 2020,
with the current average number of legal operations professionals in participating legal departments being
4.3 compared to 5.9 in 2020. The breakdown of the results by company size shows a particularly large
average number of legal operations professionals in companies with under US $1 billion in revenue in 2020
(4.5 legal operations professionals), but the overall trend since 2017 remains positive. In 2022, the average
size of the legal operations team for companies under US $1 billion is 2.4, and eight for larger companies,
compared to averages of 0.8 and 5.4 in 2017, when we first tracked this metric in the CLO Survey. The
median remains stable since 2020 at one legal operations professional per participating legal department.

*Questions were not asked in 2019.

acc.com/surveys | 19
SECTION 1: THE CHIEF LEGAL OFFICER’S ROLE AND REACH

Do you anticipate your department’s staffing levels will decrease, stay

the same, or increase in the next 12 months?
Forty-five percent of participating CLOs expect to hire more lawyers in 2022, while 50 percent expect
the number of lawyers in the legal department to remain the same. In last year’s report, only 32
percent of participants expected to hire more lawyers in 2021.

Across all other legal department positions, a majority of CLOs expect no change in staffing
numbers, with only a small minority of participants expecting the headcount to decrease. The
percentage of CLOs who expect to hire more staff this year, however, increases across all legal
department positions: paralegals (29 percent compared to 20 percent in 2021), privacy professionals
(19 percent to 14 percent), administrative staff (14 percent to 10 percent), other professionals (16
percent to 12 percent), and legal operations professionals (16 percent to 13 percent).

INCREASE STAY THE SAME DECREASE NOT SURE

Lawyers 45% 50% 1% 4%

Paralegals 29% 64% 1% 6%

Legal operations
professionals
16% 74% 2% 8%

Privacy
professionals
19% 69% 0% 12%

Administrative
staff
14% 75% 3% 8%

Other allied
professionals
16% 73% 1% 10%

20 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY COMPARISON
Percentage of departments that expect to hire lawyers in 2022 by industry
Expectations about hiring more lawyers in 2022 vary substantially by industry, from practically seven in
ten CLOs in the information industry expecting to hire more lawyers next year compared to just three in
ten among those in the construction sector. A majority of participants in the agriculture, management
of companies, food and accommodation, finance and banking, and retail industry sectors expect to hire
more lawyers in 2022.

INFORMATION 68%

AGRICULTURE, FORESTRY, FISHING, AND HUNTING 58%

MANAGEMENT OF COMPANIES AND ENTERPRISES 56%

ACCOMMODATION AND FOOD SERVICES 53%

FINANCE AND BANKING 53%

RETAIL TRADE 53%

ARTS, ENTERTAINMENT, AND RECREATION 47%

PROFESSIONAL, SCIENTIFIC, AND TECHNICAL SERVICES 46%

HEALTHCARE AND SOCIAL ASSISTANCE 43%

INSURANCE 43%

TRANSPORTATION AND WAREHOUSING 42%

OTHER SERVICES 41%

WHOLESALE TRADE/DISTRIBUTION 40%

MINING, QUARRYING, AND OIL AND GAS EXTRACTION 39%

MANUFACTURING 38%

REAL ESTATE, RENTAL AND LEASING 36%

UTILITIES 35%

EDUCATIONAL SERVICES 31%

PUBLIC ADMINISTRATION 29%

CONSTRUCTION 28%

acc.com/surveys | 21
SECTION 1: THE CHIEF LEGAL OFFICER’S ROLE AND REACH

KEY COMPARISON
Expectations to hire more privacy professionals in 2022 are slightly different depending on whether
the participating CLO oversees the privacy function or not. As the key comparison shows, 25 percent
of the CLOs that oversee privacy expect to hire a privacy professional this year, but only 15 percent of
those who do not oversee privacy expect to do so.

Percentage of CLOs who expect to hire more privacy professionals

in 2022 among…

CLOs THAT DO
NOT OVERSEE

25%
PRIVACY

15%
CLOs THAT
OVERSEE
PRIVACY

22 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

Do you anticipate the amount of work LAW FIRMS
you send to law firms and other legal
8% 51% 41%
service providers will decrease, stay the
same, or increase in next 12 months?
Four in ten CLOs expect to send more work to law firms
OTHER LEGAL
this year, and one in four anticipates outsourcing more SERVICE PROVIDERS
legal work to alternative legal service providers (ALSPs).
Only eight percent and four percent of participants expect 4% 72% 24%
that the outsourced work to law firms and other legal
service providers will decrease this year, respectively.

In tune with the higher expectations to hire more staff

DECREASE
compared to last year, these results also show an
increase in the expectations of outsourcing more work in STAY THE SAME
2022 compared to 2021. Only 34 percent of participants INCREASE
expected to send more work to law firms last year and
18 percent expected to do the same for alternative
legal providers, as shown in the key trend chart. In fact,
the expectation to send more work to law firms had
remain rather stable since 2019, with this year’s result
representing a substantial seven-point increase.

KEY TREND
Percentage of CLOs expecting the amount of outsourced work will
increase in the coming year

2019 2020 2021 2022

41%
35% 34% 34% LAW FIRMS
OTHER LEGAL
SERVICE
22% 24%
21% PROVIDERS
18%

acc.com/surveys | 23
SECTION 2

THE LEGAL DEPARTMENT’S

VALUE TO THE BUSINESS

In this section, we explore the value that CLOs and the legal department bring to the overall
business. It includes insights on how often CLOs are involved in key corporate meetings and
play a role in decision-making processes. We further explore the most relevant issues for the
organization and the legal department’s current top strategic priorities.

SECTION HIGHLIGHTS

77% of CLOs “almost always” attend their

organization’s board of directors meetings 98%
Nearly all respondents
are consulted by the

8.1
Cybersecurity and compliance remain the company’s leadership
most important issues for the business on strategic business
according to CLOs, with an average score decisions at least
of 8.1 in a 1-to-10 importance scale “sometimes”

36% 57%
A majority of CLOs reported that their
organization has a comprehensive
data management strategy to ensure
CLOs now spend over compliance, defensibility, and security
one-third of their time
contributing to business
strategy and advising
executives compared
to just 28 percent
SEVEN CLOs report that legal operations
in one of the top three key strategic

in TEN
providing legal advice initiatives currently underway in
their legal department

24 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

In order to evaluate the impact and influence of CLOs in the business, we asked
participants how often they get involved in five different situations. The general trend
shows that fewer CLOs “almost always” get involved in the scenarios we inquired
about compared to previous years.

Seventy-seven percent of participants declared that they almost always attend board
meetings, which is in line with the results observed since 2020. Sixty-eight percent
indicated that they almost always meet with business leaders to discuss operational
issues and risks areas. Although this number is down two points since 2021 and eight
since 2020, two thirds of participating CLOs have a direct and constant influence in the
company’s assessment of operational and risk issues.

The percentage of participants that are almost always consulted on business

decisions by the company’s leadership is 63 percent, also down compared to last year
by seven points. An additional 35 percent of participating CLOs, however, declared that
they are “sometimes” consulted, which accounts for 98 percent of participants being
consulted on business decisions to some degree. In any case, a solid majority of CLOs
almost always get involved in these three situations.

Forty-four percent of respondents almost always meet with the board in executive
sessions, a result that has remained stable since 2020. An additional 27 percent
participate in executive board and committee sessions at least sometimes, for a
combined seven in ten participating CLOs having some degree of influence in these
settings. Finally, one in four participants almost always meet with board members
outside of executive sessions, which represents a slight decrease compared to the
result observed in 2021. An additional 44 percent of CLOs sometimes have business
calls or meetings with board members outside of executive sessions, bringing the
number of participants that occasionally take part in this situation to 70 percent.

“For CLOs to be most effective, they must

have a deep knowledge of their organization’s
business operations and build a good rapport
with the rest of the executive leadership team.”

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SECTION 2: THE LEGAL DEPARTMENT ’S VALUE TO THE BUSINESS

KEY TREND
CLO’s input and influence based on the percentage of respondents
who “almost always” are involved in the following situations:

2017 2018 2019 2020 2021 2022

When your organization 78% 77%

74% 76%
holds a board meeting, 69% 68%
how often do you attend?

How often do you meet

with business leaders 75% 76%
at your organization 70%
66% 68%
to discuss operational 64%
issues and risk areas?

73%
How often does the 70% 70%
executive leadership 63%
team seek your input on 59% 59%
business decisions?

How often do you meet 45% 44% 44%

in executive sessions
with the board or any 39%
of its committees?

Outside of executive sessions

30% 29%
with the board or board
committees, how often do 25% 26%
you have business meetings
or calls with board members?

26 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

 CYBERSECURITY
Rate the following types 8.1
of issues in terms of their
REGULATION/COMPLIANCE
importance to your overall 8.1
business “1” being “very low
DATA PRIVACY
importance” and “10” being 7.7
“very high importance.”
INTELLECTUAL PROPERTY
Cybersecurity, regulation and 6.6

compliance, and data privacy remain

ONGOING/ANTICIPATED LITIGATION
the top three issues that CLOs consider
6.2
to be the most important to the
business. The average rate given by
CORPORATE SOCIAL RESPONSIBILITY
participants in a 1-to-10 scale where one
6.0
represents “very low importance” and
ten represents “very high importance” TAX
for these three issues is far ahead than 6.0
the other items listed, with cybersecurity
and regulation and compliance scoring DISPERSED WORKFORCE*
8.1, and data privacy 7.7. 5.7

These averages are slightly higher than ENFORCEMENT/INVESTIGATIONS

those observed in 2021, a pattern that
5.5
is common for all issues — the average
importance rate of all listed issues is SUPPLY CHAIN MANAGEMENT
higher than the previous year’s, except 5.5
for tax and dispersed workforce, which
was not asked. CORPORATE GOVERNANCE/SHAREHOLDER ACTIVISM
5.2
Intellectual property, and ongoing or
anticipated litigation remain the fourth COMPETITION/ANTITRUST
and fifth most important issues for the
4.8
business according to participants, but
corporate social responsibility climbs CORRUPTION/BRIBERY
to the sixth place, leapfrogging tax and 4.8
enforcement/investigations, in line with
the results observed in the previous WHISTLEBLOWER ISSUES
sections reflecting the increase in ESG/ 4.8
CSR oversight by CLOs.
SANCTIONS/EXPORT CONTROLS
At the bottom of the list, competition
4.2
and antitrust issues, corruption and
bribery, and whistleblower issues MONEY LAUNDERING
(all with an average of 4.8 on the 3.7
importance scale), sanctions and export
controls (4.2), and money laundering
(3.7) repeat as the five least important
issues to the business from last year. *Not asked in 2021. 2021 2022

acc.com/surveys | 27
SECTION 2: THE LEGAL DEPARTMENT ’S VALUE TO THE BUSINESS

Participants were asked to provide an estimate on how much time they dedicated to six different
aspects of the job in the previous year. The averages of the percentages allocated to each
type of work are reported. Providing legal advice is the task that CLOs allocated the most time,
with an average of 28 percent of their time at work. Managing legal risk came second, with 18
percent, followed by managing the legal department with 15 percent of the time. The remaining
three tasks combined, on average, to slightly over one-third of the CLOs typical workday, namely
contributing to strategy development (13 percent), board matters and governance (12 percent),
and advising executives on non-legal issues (11 percent). CLOs also dedicate, on average,
three percent of their time to other tasks, such as compliance matters, contract management,
insurance matters, mergers and acquisitions support, and privacy issues. The distribution of
CLOs’ work allocation remains practically identical to the results of the 2021 CLO Survey.

Please estimate the percentage of time

you allocated over the past 12 months
for each of the following:

Managing
legal risk
Other 18%
3%
Providing
legal advice
28%
Advising
executives
on non-legal Managing the
issues law department
11% 15%

Board matters and

governance Contributing to
12% strategy development
13%

28 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY COMPARISON
Percentage of time allocated to each type of work by company size
The following key comparison explores whether CLOs in smaller and large companies spread their time
differently across different tasks. There were no remarkable differences in companies of different sizes
related to the CLOs’ allocated time to managing legal risk, contributing to development strategy, board
matters and governance, and advising executives on non-legal issues.

The results show a relationship between company size and the time spent providing legal advice and
managing the law department. CLOs in smaller organizations tend to spend more time providing legal
advice than those in larger organizations, whereas CLOs in larger organizations dedicate more time to
managing the law department. Naturally, larger organizations tend to have also larger, more complex
legal department structures, higher staff headcount, and cover more areas of work, requiring CLOs in
these organizations to dedicate more time to managing the legal team.

On average, CLOs in smaller companies allocated twice the time to providing legal advice than
managing the law department, those in mid-size companies between US $1 billion and US $10 billion
spend 24 percent of their time providing legal advice and 17 percent managing the law department, and
those in large companies with US $10 billion or more in annual revenue spend, on average, the same
amount of time to providing legal advice and to managing the law department (21 percent).

PROVIDING MANAGING THE

LEGAL ADVICE LAW DEPARTMENT

30% 24% 21% 14% 17% 21%

Less than $1B $1B to $9.9B $10B or more Less than $1B $1B to $9.9B $10B or more

acc.com/surveys | 29
SECTION 2: THE LEGAL DEPARTMENT ’S VALUE TO THE BUSINESS

Does your organization have a comprehensive data management

strategy to ensure compliance, defensibility, and security?
Fifty-seven percent of participants reported that their organization has a comprehensive data
management strategy to ensure compliance, defensibility, and security, four points lower than the
percentage observed in 2021. In departments where the CLO oversees cybersecurity response, the
percentage of organizations that have such a data management strategy is slightly higher than the
overall result, with 61 percent. Organizations where the CLO oversees risk and information security
are also marginally more likely to have a data management strategy.

IN ORGANIZATIONS WHERE THE CLO OVERSEES…

2022 57%
CYBERSECURITY RESPONSE 61%
2021 61%

YES
RISK 60%

INFORMATION SECURITY 58%

PRIVACY 57%

COMPLIANCE 56%

INFORMATION GOVERNANCE 53%

Legal operations is the area that most legal departments are focusing on in terms of their key strategic
initiative. Seven in ten selected this area among three choices from the list provided. Just under half
of respondents indicated that right-sourcing of legal services is another key area of focus, 45 percent
emphasized litigation defensibility, and four in ten responded that cost minimization is among their top
three current priorities. Data security (34 percent) and data management (31 percent) come slightly
behind in the ranking of legal department’s most strategic initiatives.

The order of priorities has not changed much since last year, although an apples-to-apples
comparison is difficult because the question changed slightly in this current edition of the
survey. Legal operations, insourcing of legal services, and litigation defensibility were the
top three strategic initiatives in participating legal departments in 2021.

30 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

In what area does your legal
department’s most important
strategic initiative fall? Cost
minimization
40%

Legal
operations Data management
31%
69%

Data
Right-sourcing of Other security
legal services 19%
34%
47%
Litigation
defensibility
45%

One in five respondents (19 percent) indicated that one of the department’s key strategic initiatives was in
another area. The list below contains a representative summary of the areas listed by participants:

OTHER LEGAL DEPARTMENT STRATEGIC INITIATIVES

•B
 oard-related matters • Intellectual property
•C
 ompliance •M
 ergers and acquisitions
•C
 ontract management •O
 rganizational risk management
•C
 orporate governance •P
 rivacy
•D
 igitalization and efficiency •P
 roduct and strategy development
•D
 iversity, equity, and inclusion •R
 egulatory compliance
•E
 nvironmental, social, and governance support •R
 isk management
•H
 uman resources and labor relations •S
 trategic growth
• Improving processes •S
 trategy development

acc.com/surveys | 31
SECTION 2: THE LEGAL DEPARTMENT ’S VALUE TO THE BUSINESS

What actions, if any, are you taking to improve internal client

satisfaction with your department’s delivery of legal services?
More than 300 participating CLOs shared details on specific actions that they are taking in the
legal department to improve internal client satisfaction. The following figure summarizes the
rich diversity of strategies presented in five broad categories of actionable items: automate
services and implement new technology; conduct regular client surveys to receive feedback and
keep constant communications with key business stakeholders; hire more legal staff to improve
coverage; provide education and training to all staff to make better use of internal legal services;
and streamline and improve operations to be more responsive and improve turnaround times.

AUTOMATION AND TECHNOLOGY

“Automation of services for faster self-service transactions.”

“Implemented new technologies to manage workflows.”

“More integration of technology and data analysis as it

relates to legal and compliance matters.”

CLIENT SURVEYS AND

CONSTANT COMMUNICATION

“Annual survey of business leaders supplemented by

periodic informal discussions about the needs, quality and
timeliness of legal services and support.”

“Regular meetings, surveys, and informal ad-hoc

discussions with internal stakeholders.”

INCREASE HEADCOUNT

“Added headcount to continue to provide prompt service.”

“Hiring additional resources.”

“Hiring additional, more highly-qualified staff.”

32 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

 STAFF TRAINING

“More training so staff are empowered to ‘issue spot’ and

seek help early.”

“Training sessions with internal stakeholders.”

“Education, training, and outreach.”

STREAMLINE AND
IMPROVE OPERATIONS
“Streamlining and digitizing processes.”

“Building a team to insource work for both cost minimization

and quality control.”

“Develop legal operations to improve turnaround time and

meet changing needs.”

“Showing responsiveness and being a facilitator.”

“As in-house counsel, our service is based on three legs of a stool:

1. strong knowledge of applicable laws and regulations;
2. strong understanding of our business and the industries in
which we operate; and
3. being able to understand and manage the interaction between
business risk and legal risk.
If any of those three elements is missing, the stool collapses and
the attorney is not effective.”

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SECTION 3

THE POLITICAL AND

REGULATORY LANDSCAPE

In this section, CLOs shed light on the impact that political, regulatory, and social
issues have, and are expected to have, in the corporate legal department. The focus
is particularly placed on industry-specific and data privacy regulations, how the legal
department’s compliance budget has evolved, and how confident participants are about
their organization’s ability to respond to several risk threats.

SECTION HIGHLIGHTS

16% 58%
One in six CLOs in public companies reported
having received pressure from investors to
either take a public stand or refrain from taking
a public stand on political and cultural issues Most CLOs are either
moderately or very
confident that their

2/3
organization can
Industry-specific regulations will pose the biggest effectively respond to
legal challenges to organizations this year, cybersecurity breaches
according to two-thirds of participating CLOs and incidents

80%+
More than eight in ten
A majority of CLOs reported that their
organization invested in new technology last
year to comply with data privacy regulations 56%
CLOs in accommodation
and food services (85
percent), information

68%
(89 percent), and Almost seven in ten CLOs anticipate
insurance (90 percent) implementing new, strengthened
expect increased privacy processes to face upcoming litigation
regulatory enforcement and compliance threats

34 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

Have investors requested or pressured your organization
to take or refrain from taking a public stand on a particular
political or cultural issue in the past 12 months?
Only asked to those in publicly owned organizations (n = 216).

Yes, we have been pressured by

investors to take a public stand on a
particular political or cultural issue
10%

NO
84%
YES
16%
Yes, we have been pressured
to both take a public stand and
refrain from taking a public stand
5%

Yes, we have been pressured by

investors to refrain from taking
a public stand on a particular
political or cultural issue
1%

One in six CLOs in publicly owned

organizations reported that the 2022 16%
company had received pressures
or requests from investors to take 2021 15%
or refrain from taking a public
stand on a cultural or political
issue. This is practically the
same result observed in 2021. PERCENTAGE OF
ORGANIZATIONS THAT
Ten percent of participants in public
companies reported pressures from
RECEIVED PRESSURE
investors to take a public stand on a FROM INVESTORS
particular socio-cultural issue, while
only one percent reported pressures
to refrain from taking a position. Five
percent of CLOs reported having
received pressures in both ways.

acc.com/surveys | 35
SECTION 3: THE POLITICAL AND REGULATORY LANDSCAPE

Which of the following issues are most likely to cause the biggest legal
challenges for your organization? Please select all that apply.
Industry-specific regulations are expected INDUSTRY-SPECIFIC REGULATIONS
to cause the biggest legal challenges this 61%
66%
year, according to CLOs. Sixty-six percent
selected this issue from a list of nine areas
DATA PROTECTION PRIVACY RULES
for concern, a five-point increase compared 54%
to last year’s survey. Respondents in all 55%
global regions, with the exception of Latin
America, expect that regulations will pose MERGERS AND ACQUISITIONS
32%
the biggest legal challenges in 2022. 39%

A majority of CLOs (55 percent) also

POLITICAL CHANGES
selected data protection privacy rules as 38%
a challenging issue for legal departments 36%
and organizations worldwide, including
a majority of respondents in Europe, TAXATION
23%
Middle East, and Africa (59 percent), North 23%
America (56 percent), and the Asia-Pacific
region (52 percent). CLOs in Latin America CLIMATE/ENVIRONMENTAL CHANGES
are more concerned about taxation (65 15%
22%
percent) and political changes (61 percent)
to cause the biggest legal challenges to
TARIFFS AND OTHER TRADE-RELATED ISSUES
businesses in that region. 18%
18%
Slightly over one-third of respondents
overall also list mergers and acquisitions ANTITRUST AND COMPETITION ENFORCEMENT
(39 percent, seven points higher than last 12%
17%
year) and political changes (36 percent)
as causing potential legal challenges,
CHANGES TO FOREIGN DIRECT INVESTMENT RULES
while 23 percent globally believe that 6%
taxation will also create legal issues for 7%
companies, and 22 percent expect climate
and environmental changes to impact OTHER
8%
companies legally (a seven-point increase 10%
compared to last year).

Tariffs (18 percent), antitrust and

competition enforcement (17 percent), 2021 2022
and changes to foreign direct investment
rules closed the list. One in ten CLOs listed
other areas of concern, especially matters
related to the ongoing Covid-19 pandemic:
changing regulations, remote workforce,
and vaccine mandates.

36 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY COMPARISON
Issue most likely to cause the biggest legal challenges by global region

ASIA-PACIFIC EMEA LATIN AMERICA NORTH AMERICA

Industry-specific
59% 72% 45% 68%
regulations

Data protection privacy

52% 59% 29% 56%
rules

Mergers and
33% 41% 32% 40%
acquisitions

Political changes 30% 30% 61% 36%

Taxation 17% 26% 65% 22%

Climate/environmental
35% 24% 35% 17%
changes

Tariffs and other trade-

15% 13% 29% 18%
related issues

Antitrust and
competition 25% 31% 29% 12%
enforcement

Changes to foreign
14% 6% 16% 4%
direct investment rules

Other 7% 11% 13% 10%

acc.com/surveys | 37
SECTION 3: THE POLITICAL AND REGULATORY LANDSCAPE

How confident are you in your organization’s ability to mitigate

against emerging risks?
CLOs remain confident that the organization will be able to mitigate against emerging risks, with
seven in ten participants being either very confident or moderately confident. This is similar to what
was observed in 2021, but fifteen points higher than the results from the 2020 survey. The 2020
data was collected before the outbreak of the Covid-19 pandemic, with the recent results perhaps
pointing to an increased confidence among CLOs in their organizations’ ability to mitigate against
emerging risks as a result of the upheaval caused by the global pandemic in 2020 and beyond.

2022
25% 44% 25% 5% 1%

2021
25% 45% 24% 5% 1%

2020
12% 42% 34% 11% 1%

VERY MODERATELY SOMEWHAT ONLY SLIGHTLY NOT AT ALL

CONFIDENT CONFIDENT CONFIDENT CONFIDENT CONFIDENT

Almost half of respondents indicate that the changing privacy landscape in the United States is either
highly or moderately impacting the business (48 percent). Not surprisingly, CLOs in the U.S. report the
highest levels of impact on the business of new privacy regulations and concerns, with 22 percent
saying the company has been highly impacted, and 36 percent reporting a moderate impact. Only two
percent of U.S.-based participants responded that the changing privacy landscape has not had any
impact on the organizations.

Changing privacy laws in the U.S. have impacted organizations headquartered elsewhere to a lesser
extent, with 39 percent of participating CLOs in Europe, Middle East, and Africa reporting either a
high or moderate impact on the business, 29 percent of those based in Latin America, 27 percent of
those located in Asia, and 17 percent of those in Australia-Pacific reporting higher or moderate levels
of impact on business operations. Interestingly, only five percent of CLOs in Canada reported that
the changing privacy landscape in the U.S. is highly impacting the business, though an additional 21
percent reported a moderate level of impact.

38 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY COMPARISON
How do you see the changing privacy landscape in the U.S. impacting
your business operations?

OVERALL RESULTS
18% 30% 26% 19% 8%

By global region:

UNITED STATES
22% 36% 26% 14% 2%

EMEA
13% 26% 35% 11% 15%

LATIN AMERICA
10% 19% 19% 29% 23%

ASIA
8% 19% 29% 32% 12%

AUSTRALIA/PACIFIC
7% 10% 19% 34% 30%

CANADA
5% 21% 24% 34% 16%

HIGHLY MODERATELY SOMEWHAT SLIGHTLY SLIGHTLY

IMPACTED IMPACTED IMPACTED IMPACTED IMPACTED

acc.com/surveys | 39
SECTION 3: THE POLITICAL AND REGULATORY LANDSCAPE

KEY COMPARISON
How confident are you in your organization’s ability to consistently and
defensibly respond to cybersecurity incidents and breaches?
Fifty-eight percent of CLOs are at least moderately confident that their organizations can consistently
and defensibly respond to cybersecurity breaches and incidents, a result three points higher than
the observed in 2021. Twenty-nine percent responded that they are somewhat confident, 12 percent
said they are only slightly confident, and just two percent reported not being confident at all in their
organizations’ ability to effectively respond to cyberthreats.

Sixty percent of the CLOs that oversee privacy are at least moderately confident that the organization
can successfully defend itself from cybersecurity incidents and breaches. Fifty-eight percent of CLOs
that oversee risk are moderately or highly confident, but just 54 percent of participants who oversee
cybersecurity response are equally confident, which still represents a majority within this group
but is slightly lower than the overall result. Rather than having lower confidence in the company’s
cybersecurity efforts, CLOs who lead cybersecurity response may be better aware of the challenges
and complexities posed by cyberattacks.

15% 43% 29% 12% 2%

OVERALL 2022
RESULTS 2021
15% 40% 31% 12% 2%

VERY MODERATELY SOMEWHAT ONLY SLIGHTLY NOT AT ALL

CONFIDENT CONFIDENT CONFIDENT CONFIDENT CONFIDENT

Among CLOs who oversee...

PRIVACY
16% 44% 40%

RISK
14% 44% 42%

CYBERSECURITY
RESPONSE
17% 37% 46%

VERY MODERATELY SOMEWHAT CONFIDENT

CONFIDENT CONFIDENT OR LESS

40 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

How have you prepared IMPLEMENTED
your organization for
TECHNOLOGY SOLUTIONS
complying with data 56%
56%
privacy regulations in
the past 12 months?
(Select all that apply.) INCREASED USE OF
Faced with the complexity of OUTSOURCED NON-LAW
complying with all existing data
privacy regulations, most CLOs
FIRM VENDORS
27%
indicated that they implemented 31%
new technology solutions in
the last year to ensure that
customer and corporate data
are safe. Thirty-one percent
INTERNAL RESTRUCTURING
26%
of participants increased the 27%
use of outsourced non-law firm
vendors to provide expertise
and services in accomplishing
this critical task, and 27 percent EMPLOYED A DEDICATED LEGAL
indicated that they did some OPERATIONS PROFESSIONAL(S)
internal restructuring to address 19%
the issue of privacy compliance. 19%
Nineteen percent employed a
legal operations professional to
support data privacy compliance. OTHER
7%
Other initiatives taken by 12%
12 percent of CLOs include
employing a dedicated data
privacy professional, designing NOTHING
and implementing data privacy 15%
policies, and providing staff 15%
with education and training.
Fifteen percent of CLOs, however,
admitted that they did nothing
additional in the last year to 2021 2022
prepare the organization for
complying with existing and
OTHER INITIATIVES
new data privacy regulations.
• compliance policies and frameworks
•e
 ducation and training for staff
•e
 mployed a data privacy professional
• increased use of law firms

acc.com/surveys | 41
SECTION 3: THE POLITICAL AND REGULATORY LANDSCAPE

How do you anticipate the volume of privacy regulatory

enforcement in your industry changing in the next 12 months?

Six in ten CLOs expect an increased amount

of privacy-related regulatory enforcement in
the coming year, while the rest of participants
believe that regulatory pressure will not change.
Not a single participating CLO believed that
the volume of regulatory enforcement in the
privacy area would ease moving forward.

However, there is substantial variation

across industries in the CLOs’ expectations
INCREASE on whether privacy regulation enforcement
60% would increase in the next 12 months. Across
all industries except for management of
companies, utilities, public administration,
construction, and mining, at least half of
participants believed the volume of privacy
regulatory enforcement would increase.

Such an increase is overwhelmingly expected

from CLOs in the insurance, information, and
accommodation and food services industries,
with 90 percent, 89 percent, and 85 percent,
respectively. CLOs in finance and banking
(71 percent), education (69 percent), retail
(66 percent), transportation (64 percent),
and healthcare (61 percent) also expect an
increased enforcement of privacy regulations
NO CHANGE above the overall survey’s average (60 percent).
40%

DECREASE
0%

42 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY COMPARISON
Percentage of CLOs who expect increased privacy regulatory
enforcement by industry

INSURANCE 90%

INFORMATION 89%

ACCOMMODATION AND
FOOD SERVICES
85%

FINANCE AND BANKING 71%

EDUCATIONAL SERVICES 69%

RETAIL TRADE 66%

TRANSPORTATION AND
WAREHOUSING
64%

HEALTHCARE AND SOCIAL

ASSISTANCE
61%

PROFESSIONAL, SCIENTIFIC,
AND TECHNICAL SERVICES
59%

OTHER SERVICES 56%

ARTS, ENTERTAINMENT,
AND RECREATION
53%

WHOLESALE TRADE/
DISTRIBUTION
52%

REAL ESTATE, RENTAL

AND LEASING
52%

MANUFACTURING 50%

AGRICULTURE, FORESTRY,
FISHING, AND HUNTING
50%

MANAGEMENT OF COMPANIES
AND ENTERPRISES
44%

UTILITIES 43%

PUBLIC ADMINISTRATION 43%

CONSTRUCTION 28%

MINING, QUARRYING, AND OIL

AND GAS EXTRACTION
11%

acc.com/surveys | 43
SECTION 3: THE POLITICAL AND REGULATORY LANDSCAPE

Over the past 12 months, did your department’s

expenditures increase for regulatory compliance?
A majority of legal departments report an increase in the spending allocated for regulatory
compliance in the last year. Although slightly higher than the 2021 result (50 percent), the
percentage of departments that increased their compliance-related expenses is slightly
lower than that registered in the 2020 survey. However, at least 50 percent of departments
reported an increase in compliance expenditures across the last three editions of this survey.

2020 2021 2022

YES 58% YES 50% YES 54%

Over the next 12 months, are your department’s expenditures

expected to increase for regulatory compliance solutions?
A plurality of legal departments (32 percent) expect that compliance expenditures will increase
“somewhat”, while 20 percent expect a moderate increase, and five percent of participants
expect a high increase in compliance related expenses. Fifteen percent of participants
responded that their legal department will not spend more on compliance in 2022.

Highly
Moderately Somewhat Only slightly Not at all
20% 28% 15%
5% 32%

44 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY COMPARISON
Expenditures for regulatory compliance solutions expected to
increase based on whether they increased last year
The following key comparison explores the compliance spending patterns of legal departments.
We classify legal departments depending on whether their compliance-related expenses
increased last year and see what the expectations on increased compliance spending reported by
CLOs in 2022. The results are interesting.

Departments that reported an increased spend on compliance last year are more likely to also
spend more this year, whereas departments that did not increase their spending las year are
more likely to keep it the same way in 2022. Put differently, 75 percent of the departments which
increased compliance spending last year will at least increase compliance spending somewhat in
2022; while only 34 percent of departments that did not increase compliance expenses last year
will do so this year.

Compliance
expenditures did not
increase in 2021
7% 27% 35% 30%

Compliance
expenditures
increased in 2021 9% 30% 36% 22% 3%

HIGHLY MODERATELY SOMEWHAT ONLY SLIGHTLY NOT AT ALL

acc.com/surveys | 45
SECTION 3: THE POLITICAL AND REGULATORY LANDSCAPE

How are you planning to increase defensibility against

litigation and compliance threats (cyberattacks, data
breaches, regulatory fines, civil litigation sanctions)?

Survey respondents prefer

a comprehensive approach
to increase the company’s
defensibility against litigation Investment
and compliance threats, in additional
including cyberattacks, data personnel
breaches, regulatory fines, and 32%
other civil litigation sanctions.
Two-thirds of participating
New
CLOs plan on establishing processes
new process to increase
defensibility, and over a half
68%
also intend to invest in new
Investment
technology and consult with in new
third parties to limit exposure technology
to litigation and compliance 56%
threats. An additional one-
third of participants intends to Other
invest in additional personnel 3%
to support this critical goal.
Other strategies shared by
CLOs include increased
3rd party
education and training for consultation
staff and maximizing the 55%
efficiency of the current
technological resources.

“Continuously develop and improve the

legal operations service catalog to improve
turnaround time and meet changing needs; and
engage with leadership on data governance
issues and cyber-risk management.”

46 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

Please list any macro trends causing your organization to improve its
compliance efforts:
In this open-ended question, 238 participants shared their thoughts on the ongoing trends that are causing
organizations to dedicate more efforts to compliance. Almost two-thirds of participants point to the existing
regulatory environment across multiple jurisdictions as the main driver of enhanced compliance effort, 41
percent specifically refer to privacy regulations and mitigating cybersecurity risks, and 39 percent say that
the current focus on environmental, social, and governance is guiding the company’s efforts on improved
compliance. About 18 percent of CLOs listed additional trends.

64% REGULATIONS
The current regulatory environment and the expectations that regulatory
enforcement will increase in the next year is listed by 64 percent of participants
as one of the main drivers of enhanced compliance efforts in the organization.

41% PRIVACY AND CYBERSECURITY

The focus on privacy regulations across multiple countries and jurisdictions
(China, European Union, United States, including California) is forcing
companies to step up its compliance efforts, as well as cybersecurity risks.

39% ESG
CLOs also list environmental, social, and governance issues as a key reason
to improve the organization’s compliance efforts, with many citing the need
to comply with new environmental rules to combat climate change, and the
strong focus that investors are putting on ESG and CSR.

18% OTHER TRENDS

Other efforts to improve compliance respond to demands from customers
and investors (6 percent), supply chain disruptions and shortages (4
percent), global and domestic economic and political changes (4 percent),
employment issues, including adjusting to the new work environment post-
Covid (3 percent), and diversity and inclusion initiatives (1 percent).

acc.com/surveys | 47
SECTION 4

THE OUTLOOK FOR

THE LEGAL DEPARTMENT

This final section summarizes the views and expectations of participating CLOs on the corporate
legal department’s immediate future. We explore which areas CLOs expect to invest more in the
next year, from strategic initiatives to legal technology, and their thoughts on their organizations’
most important strategic priorities in the near future. Participants also provided insights on the
key business skills that they seek to develop for the lawyers in the legal department, and shared
valuable wisdom about the ins and outs of the position for aspiring CLOs.

SECTION HIGHLIGHTS

25%
One quarter of respondents believe that
M&A is the issue that will require the most
additional legal resources in the coming year
84%
Five in six CLOs expect
greater collaboration
between legal and other

43%
departments due to
43 percent of CLOs anticipate implementing increased regulations
new technology solutions in the legal and the need to optimize
department this year internal processes

50%+
Leadership (61 percent),
Among those who will invest
in new technology, 7 in 10 will
update or invest in new contract
management technology
SEVEN
in TEN
communication (58 percent),
business management (56
percent), and executive

1st
presence (50 percent) are Delivering value to customers remains
the most common skills that the top organizational priority in the
CLOs seek to develop for the next five years, according to half of
lawyers in their department participating CLOs

48 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

Please select one area that SIGNIFICANT TRANSACTIONS (M&A, SPIN-OFFS, ETC.)

you think will require the 25%

most additional resources
COMPLIANCE ISSUES
in the next 12 months.
16%
CLOs believe that significant corporate
transactions, including mergers REGULATORY ISSUES
and acquisitions, and spin-offs, will
be the area that requires the most
15%
additional departmental resources
in 2022. From a list of 12 topics, DATA PRIVACY/PROTECTION
25 percent of participants selected
significant transactions as the issue
13%
that will need more focus, with a
four-point increase compared to last LITIGATION/EDISCOVERY MATTERS
year. Compliance issues (16 percent)
and regulatory issues (15 percent)
8%
complete the top three, with identical
results compared to last year’s survey. CROSS-BORDER WORK/INTERNATIONAL LAW
Data privacy and protection comes
fourth with 13 percent, 9-point lower
6%
than in 2020, when CLOs thought it
would be the area that would require ENTERPRISE DIGITAL TRANSFORMATION
the most resources that year.

5%

INTELLECTUAL PROPERTY

“We are focused on 5%

engaging with the senior DIVERSITY AND INCLUSION INITIATIVES

leadership team on
3%
strategic matters, M&A
ANTITRUST ISSUES
and market development
opportunities, litigation 1%
management, employee COMPETITION LAW
safety and security, and
1%
general business advice.”
OTHER 2020
2021

4% 2022

acc.com/surveys | 49
SECTION 4: THE OUTLOOK FOR THE LEGAL DEPARTMENT

Are you planning on adopting any new legal technology solutions in

your department to improve efficiency in the next 12 months?

2022 26%

2022 43% 2021 30%

NO
2021 42%

YES
10% 12%

NO
because
we recently
adopted a
new legal
technology
solution

2022 19%

2021 19%

NOT SURE
AT THIS
TIME
Forty-three percent of participants intend
on adopting new technology solutions
in the legal department in 2022, while an
additional 12 percent indicated that they
do not intend to do it because they recently
upgraded their technology portfolio. Twenty-
six percent reported not considering adopting
any new legal technologies this year, and
19 percent are not sure yet. The results
closely resemble those observed last year.

50 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

Specifically, what legal technology are you looking to invest more in the next
24 months?
Among those who are looking into investing in new technology solutions, seven in ten stated that they want to
invest in contract management technology, which remains the most common technology are that CLOs are
considering investing on since last year, by a considerable margin. At least one in four survey participants are
looking into upgrading document management technology solutions (39 percent), workflow tools (33 percent),
collaboration and knowledge management tools (25 percent), and matter management technology (25 percent).

The results closely resemble those observed last year, with the notable exception of eSignature technology tools.
Only 22 percent of those CLOs surveyed that intend on spending in new technology solutions are looking into
investing on eSignature tools, compared to 34 percent last year. As a result, eSignature dropped from ranking
third to eight on the list. Six percent of respondents indicated other technologies aside from those listed, including
artificial intelligence technology, legal entity management tools, and third-party risk management software.

67%
CONTRACT MANAGEMENT
69%

41%
DOCUMENT MANAGEMENT
39%

32%
WORKFLOW TOOLS
33%

COLLABORATION/KNOWLEDGE 26%
MANAGEMENT 25%

22%
MATTER MANAGEMENT
25%

23%
DATA PRIVACY
23%

21%
ANALYTICS
22%

34%
eSIGNATURE
22%

20%
RECORDS MANAGEMENT
20%

16%
DATA SECURITY
14%

INFORMATION GOVERNANCE (DATA 14%

MAPPING, ETC.) 13%

8% OTHER TECHNOLOGIES
eBILLING
12%

13% • artificial intelligence

IP MANAGEMENT
12%
• board management
EDISCOVERY (LEGAL HOLD, 7%
COLLECTION, PROCESSING, REVIEW) 7% • compliance

INTEGRATION TOOLS 4% • legal entity management

5%
• corporate secretary
4%
OTHER
6% • third party risk management

2021 2022

acc.com/surveys | 51
SECTION 4: THE OUTLOOK FOR THE LEGAL DEPARTMENT

To what extent do you agree with the statement: “I am seeing and expect
to continue to see greater collaboration across legal, compliance,
privacy, and other departments due to increased regulations and need
to optimize internal processes.”
An overwhelming majority of participants (84 percent) expect collaboration across legal and other
business divisions, such as compliance and privacy, to continue growing as a result of the increased
regulations and the need to optimize internal processes. Forty-five percent of CLOs strongly agree
with this statement and an additional 39 percent agree to some extent. Fourteen percent neither
agree nor disagree to increased inter-departmental collaboration as a result of regulatory pressure,
and only three percent disagree that collaboration will increase in the near future.

45%

39%

14%

2% 1%

Strongly Somewhat Neither agree Somewhat Strongly

agree agree nor disagree disagree disagree

84%
expect greater
3%
disagree that
collaboration across collaboration will
legal and other increase in the
business divisions near future

52 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

KEY TREND
CLOs were asked to rank the following five priorities in terms of what they thought would be most
important for their organization in the next five years: dealing ethically with suppliers, delivering
value to customers, investing in employees, maximizing profits, or supporting outside communities.

The following trend shows the percentage of CLOs who selected each priority as their company’s
top choice in the last three years. Delivering value to customers remains the most common
organizational priority, with half of participating CLOs ranking this as their organization’s top
priority in the next five years. Maximizing profits remains second (26 percent) and investing in
employees (19 percent is third). It is interesting, however, how the gap between these two priorities
has closed since 2020. Maximizing profits was the top priority for 35 percent of participating
organizations in 2020 while only 10 percent selected investing in employees as the top issue to
prioritize that year, a 25-point gap. In 2021, this gap has been reduced to just seven points.

Only a combined five percent of participants selected the other two options, supporting
outside communities (three percent) and dealing ethically with suppliers (two percent), as their
organization top priority in the next five years.

Please rank the following items you foresee your organization

prioritizing over the next five years from “1” to “5,” with “1” being the
top priority, to “5” being the lowest priority.

2020 2021 2022

52%
50% 50%
Delivering value to customers

35%

Maximizing profits 30%

26%

19%

14%
Investing in employees
10%

3% 3% 3%
Supporting outside communities
Dealing ethically with suppliers 2% 1% 2%

Note: Values indicate the percentage of respondents that ranked each item as their organization’s top priority.

acc.com/surveys | 53
SECTION 4: THE OUTLOOK FOR THE LEGAL DEPARTMENT

Which of the following skills are you seeking to develop for the lawyers
in your department?
Leadership is the business skill that most participating CLOs are seeking to develop for the lawyers
in the department, according to 61 percent of participants. This result is practically the same as
that observed in 2020 (the question was not included in the survey last year). Communication and
listening (58 percent), business management skills (56 percent), and executive presence (50 percent)
are the other skills that at least half of CLOs consider key assets to the in-house counsel’s skillset.

A few skills are considerably more sought after by CLOs compared to 2020, including communication
and listening skills (13 points more), business management skills (nine-point increase), project
management (six points more), and executive presence (five points more). Conflict resolution and
cross-cultural awareness also show a four-point increase compared to 2020. Comparatively, only a
few other skills are less sought after, with emotional intelligence receding the most, from 42 percent
to 37 percent (five points).

62%
LEADERSHIP 61%

45%
COMMUNICATION AND LISTENING 58%

47%
BUSINESS MANAGEMENT 56%

45%
EXECUTIVE PRESENCE 50%

42%
PROJECT MANAGEMENT 48%

38%
PRESENTATION SKILLS 38%

42%
EMOTIONAL INTELLIGENCE 37%

34%
FINANCIAL ACUMEN 34%

26%
CONFLICT RESOLUTION 30%

61%
18%
CROSS-CULTURAL AWARENESS 22%

DATA ANALYTICS AND 20%

VISUALIZATION 19%

11% are seeking to develop

FOREIGN LANGUAGE SKILLS 11%
leadership skills for the
OTHER 2% lawyers in the department
5%

2020 2022

54 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

What advice do you have for aspiring chief legal officers?
Almost 200 participants provided a few words of advice to aspiring or new chief legal officers and general
counsel. The following diagram presents a mock Q&A session with our experienced participants providing
useful answers and tips for aspiring CLOs that ask the following hypothetical questions. The quotes from

QA
survey participants have been edited for styling reasons and to preserve anonymity, if applicable.

IS THE CLO ROLE MORE ABOUT BEING A

LEGAL ADVISOR OR A BUSINESS PARTNER?

“Be a business leader first, then a legal advisor.”

“Be a trusted advisor that delivers commercial

practical solutions.”

“Be cognizant of the balance between legal risk and

business priorities.”

“Be part of the solution, not part of the problem.”

“Become more of a business partner than a lawyer, meaning

you must understand the business in order to be an effective
chief legal officer.”

“Help your business partners find solutions, not roadblocks.”

“Do all you can to understand the business, and find ways
to become a trusted business partner and advisor, not just
a legal advisor.”

“Go beyond just ‘being a lawyer’ and try to become viewed as a

valued business partner.”

“Perform the difficult work of understanding the business. I

spend more time providing business advice than legal advice.”

“Understand that legal management is different from lawyering

and remember that we serve the business.”

“We provide a service. Learn the business inside and out to

maximize your value.”

“You cannot provide the highest levels of service to your

company if you do not fully understand what it does.”

acc.com/surveys | 55
QA
SECTION 4: THE OUTLOOK FOR THE LEGAL DEPARTMENT

WHAT ARE KEY SKILLS I SHOULD DEVELOP?

“Always learn and always listen.”

“Be curious and strive to learn from every situation you face.”

“Broaden your skill set and show interest in a variety of areas

and projects.”

“Continue to improve your ability to communicate complex legal

concepts in a ‘business-friendly’ manner.”

“Develop resilience and executive leadership skills. You are

already a good lawyer.”

“Gather as much breadth in your experience as possible! The

more you learn, the better you will lead!”

“Learn how to be concise. Executives and board members do not

have patience for long-winded discussions.”

“Portray confidence, transparency, and authenticity.”

“Have confidence in your ability to adapt and learn new things.”

“Learn to walk a tight rope as you need to protect the company

while not getting in the way.”

“Listen carefully and remember we are ‘helpers’ to others.”

“Never stop learning. Be courageous about trying new things.”

“Read all you can on leadership to help you develop and define
your leadership style.”

“Understand that your network is an extremely valuable asset,

invest in it.”

“Work hard.”

“Learn to communicate effectively and efficiently.”

56 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

QA
WHAT MATTER MOST WHEN BUILDING
MY TEAM?

“Be a generalist and don’t expect to be an expert at anything.

Surround yourself by people who can best get you the answers
you need as quickly as possible and let them know how much
you appreciate them always being available.”

“Build a team with people that enjoy going to work and that
support each other. Be generous with positive feedback.”

“Surround yourself with smart people whose judgment you trust.”

“Hire great talent.”

“Put the best team in place so you can and rely on them.”

“The more you invest in the development of your team, the

better your team will function and the more likely you’ll achieve
success yourself.”

“Without a team, you cannot do your job. Invest time and

resources in it.”

“Show leadership, inclusivity and diversity focus, and invest time

in the development of your team.”

acc.com/surveys | 57
QA
SECTION 4: THE OUTLOOK FOR THE LEGAL DEPARTMENT

WHAT SORT OF RELATIONSHIPS

SHOULD I DEVELOP?

“The more value you can provide to your executive team and the
more they trust you, the better for the business.”

“Always start with ‘how can I help you’?”

“Broaden your legal and business knowledge and your network at

every opportunity because the CLO needs broad, comprehensive
knowledge and contacts.”

“Build good relationship with your business partners, listen to

what they say, and help identify how you can help them reach
their goals while remaining compliant.”

“Develop strong relationships with peers and executives.”

“Develop relationships with key players, leaders, and information

holders across the company.”

“Develop strong relationships with executives, where you are a

trusted partner.”

“Make yourself an indispensable partner and resource for not

only legal issues but business as well.”

“Participate in as many of the business strategy discussions and

planning sessions as you can.”

“Business people want pragmatic legal advice and will afford

greater respect to a CLO whom they view as being informed and
experienced regarding business.”

“Invest in building relationships with your colleagues as having

their trust is paramount — high performance executive teams
are based on trust.”

58 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

QA
ANY OTHER ADVICE FOR AN ASPIRING CLO?

“Get involved with professional organizations, like the amazing

Association of Corporate Counsel.”

“Join ACC, particularly if you have a small legal department.”

“Speak to experienced CLOs and CEOs, ask them questions,

find a mentor.”

“Seek out a mentor. The ACC has a great program.”

“Tap into the excellent resources ACC has to offer and especially
those directed at new GCs/CLOs and small law departments.”

“It’s a fun, fast-moving, challenging, but rewarding position.”

acc.com/surveys | 59
PARTICIPANT PROFILE
Geographic location of participants

UNITED STATES 67%

ASIA 10%

AUSTRALIA/PACIFIC 9%

EMEA 6%

CANADA 5%

LATIN AMERICA 4%

COUNTRIES REPRESENTED

60 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

What is your organization’s industry affiliation?

Manufacturing 19%

Healthcare and social assistance 11%

Other services 11%

Information 9%

Finance and banking 8%

Professional, scientific,
8%
and technical services

Construction 4%

Insurance 4%

Retail trade 4%

Educational services 3%

Real estate, rental and leasing 3%

Transportation and warehousing 3%

Utilities 3%

Wholesale trade/distribution 3%

Accommodation and food services 2%

Arts, entertainment, and recreation 2%

Mining, quarrying, and oil

2%
and gas extraction
Agriculture, forestry,
1%
fishing, and hunting
Management of companies
1%
and enterprises

Public administration 1%

Administrative and support and waste

0%
management and remediation

acc.com/surveys | 61
PARTICIPANT PROFILE

Which of the following What is the total number of

describes your organization? employees in the organization’s law
Please select all that apply. department, including all locations?

Private 59% 11% 1 employee

Public 25% 36% 2 to 5 employees

Non-profit
organization 10% 14% 6 to 9 employees

Wholly owned
subsidiary 8% 14% 10 to 24 employees

Government 1% 7% 25 to 49 employees

Joint venture 1% 18% 50 or more employees

Other 3%

62 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

 Including yourself, what is the Please select the category that
total number of lawyers in your law represents your organization’s
department, including all locations? worldwide total gross revenue for the
last reported fiscal year in US dollars.

1 lawyer 26%
27% Less than US $100M

2 to 5 lawyers 41%
27% US $100M to US $499M

6 to 9 lawyers 12%
29% US $500M to US $2.9B

10 to 24 lawyers 11%
17% US $3B or more

25 to 49 lawyers 5%

50 or more lawyers 5%

acc.com/surveys | 63
METHODOLOGY
SURVEY INSTRUMENT
The survey questionnaire was offered through an online survey platform. Personalized survey links were
sent by email to the target population, which allowed participants to save their responses and fill out the
questionnaire in more than one sitting, if needed.

FIELDING PERIOD
The survey opened on September 9, 2021, and closed on October 31, 2021. Reminder emails were sent weekly.

TARGET POPULATION
We targeted ACC members worldwide who are the highest-ranked legal officers in their respective legal
departments. A screener question was asked to help determine the most relevant population. To further
expand our reach, we also sent participation invites through other ACC partner organizations.

PARTICIPATION
A total of 861 CLOs participated. Apart from targeted email messages, opportunities to participate were also
sent through LinkedIn campaigns.

ANONYMITY
Survey responses were completely anonymous. No information is linked in any way to an individual
respondent. The results are provided only at the aggregate level, and respondents’ quotes from open-ended
responses were carefully reviewed and edited, if necessary, to remove any identifiable information related to
respondents or their organizations.

DATA ACCURACY
Not all respondents answered all questions. The percentages provided are based on the number of valid
responses received for each individual question. Many survey questions offered the opportunity to select
multiple response options. In those cases, percentages may not total to 100 percent.

OPEN-ENDED RESPONSES
Several survey questions required open-ended responses. Many of the quotes and citations from participants
that we present throughout the report were shortened or edited due to space or style needs.

STATISTICAL TERMINOLOGY
Mean: The values of each observation are summed together and divided by the total number of observations
(also called the average).

Median: This is the middle value of all observations ordered from low to high (also called the 50th percentile).

n: This indicates the number of observations for a given metric or reported value.

64 | 2022 ACC CHIEF LEGAL OFFICERS SURVEY

ABOUT ACC ABOUT EXTERRO
The Association of Corporate Counsel (ACC) is a Exterro was founded with the simple vision that
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professional and business interests of in-house data science to how companies manage digital
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networking opportunities and advocacy initiatives. committed to this vision today. We deliver a fully
With more than 45,000 members employed by over integrated Legal GRC platform that enables our clients
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To learn more about ACC’s Research & Insights please law enforcement and government agencies work
contact ACC Research at +1.202.293.4103 or visit smarter, more efficiently, and support the Rule of Law.
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