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Reflecting on Ethics and Compliance in the Nordic Region

December 4, 2023

The Nordic Business Ethics (NBE) Initiative is continuing its mission to provide professionals and organizations with region-specific insights on business ethics in practice. In November 2023, the NBE released the results of their annual survey, this time focused on Ethics & Compliance (E&C).  

“FRA is proud to sponsor this effort year on year since its inception in 2019, in line with our commitment to help clients make the most of international best practices and local expertise.” - Viktor Josefsson, FRA’s Head of Nordics

To discuss key learning points from this year’s survey, NBE co-founder Niina Ratsula hosted a panel in DLA Piper’s Helsinki office. The NBE survey shows progress in compliance culture and processes in the region over five years, although the panellists agreed there was still much room for improvement to catch up with jurisdictions like the US and UK.

NBE panellists in Helsinki, Nov 2023. Left to right: Suzanne Innes-Stubb (VP Global Compliance at Kone Corporation), Salla Tuominen (Head of Corporate, DLA Piper), Niina Ratsula (NBE co-founder), Anushka Ram (FRA Director) and Satu-Anneli Kauranen (Senior Counsel, DLA Piper). Photo credit: NBE

Better resources are needed to improve effectiveness

The top three challenges respondents reported for their E&C teams included manual processes and lack of system support, limited budget and resources, and gauging actual impact on culture and business practices.  

“From an investigations point of view, you certainly now need a more forensic mindset. From the DOJ’s Evaluation of a Compliance Program there’s also quite a focus on testing and continuous monitoring, and a lot of that comes with having an analytical skillset, forensic mindset. Another crucial area is ensuring proper document retention, have you got your repositories sufficiently organised for you to be able to quickly access and demonstrate your defensibility.” – Anushka Ram, FRA Director

Recurring survey responses also indicated a lack of risk management, screening, monitoring and other IT tools. These tools are essential particularly to the effectiveness of proactive risk managements in a centralized compliance model, which 84% of survey respondents claims to have in their organizations.

E&C teams are more professionally diverse  

The survey showed that more people with business administration and management background were now working in this field alongside the more typical lawyer profiles, which the panellists also observed in their own experience. FRA’s Anushka Ram, who recently completed a six-month secondment as Chief Compliance Officer to an international chemical distribution and logistics company in Europe, agreed that having compliance team members with diverse backgrounds and skillsets helped the compliance function perform more effectively and ultimately be more successful.  

Whistleblowing systems are in place, the right skills are needed to follow up

It is encouraging that the survey showed 98% of organisations had adopted anonymous whistleblowing systems. With 73% managed via an internal function, this calls for the right skills to handle the growing number of reports efficiently. Internal processes needed include a clear triage system to ensure investigations, confidentiality, follow up with whistleblowers and remedial actions where needed.

Read the NBE survey results here.

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