Newsletter | Volume 1

Issue I
Issue II
Issue III
Issue IV
Issue V
Issue VI
Issue VII
Issue VIII
Issue IX
Issue X
Issue XI
Issue XII
Issue XIII
Issue XIV
Issue XV
Issue XVI
Issue XVII
Issue XIX
Issue XX
Issue XXI
Issue XXII

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From Bribery and anti-corruption visibility to Creation of Values and good conduct

As we approach the fiscal year end, companies must look into the additional disclosures and reports requirements on environmental, social and employee-related issues, concerns regarding respect for human rights, CSR and many other 'soft law' components, can be under the auspices of the United Nations Global Compact, the Global Reporting Initiative (GRI) or similar.

To maintain the current focus on accountability and transparency we suggest steps that ensure disclosure uniformity. The compliance reporting framework will comprise of positive results achieved by the implemented good governance, risk management and compliance (GRC) policies related to CSR and BFC. They will determine how the company manages these risks, associated with all of the above components.

Zero-tolerance as a golden rule
The primary purpose of compliance is to create value if the GRC actions are more accountable and transparent. Instead of regarding the new reporting requirements as a single one-off, non-renewable initiative, we recommend that companies take a more holistic GRC approach. We often see that a controlled GRC design provides the right answer, solution and the opportunity to achieve far greater compliance and understanding. Visibility also provides the capability so that all corporate managers and employees understand anti-corruption GRC agenda seriously. Thereby the established zero-tolerance practice makes sense and does not simply act as a golden rule.

The anti- Bribery, Fraud, Corruption and CSR Assessment Value Proposition
Bribery and Corruption enforcement actions have recently been increasing, and will likely continue to be a hot topic in 2014. BFC and CSR related issues can potentially involve all parts of an organization, affiliates, suppliers and other third-party associates. Organizations and individuals found to have violated the BA/FCPA and EU mandates may be subject to a variety of consequences; including significant fines, costly litigation, reputational damage, destabilization of the stock price and the inability to bid on contracts.

Companies with strong compliance programs will likely be better positioned to prevent and identify and reduce potential BFC violations. The Copenhagen Compliance framework and roadmap provides guidance to assess whether management is maintaining an effective compliance program to address the GRC/BFC/CSR risks. Each assessment results in recommendations to management and C-suite officers on improving the components of an effective compliance program in order to measure its effectiveness.

An effectively designed, implemented, and managed compliance program, tailored to a company's specific risks, provides the principal key to GRC success. We have developed a complete range of assessment tools, technique and methodology to assess the current GRC procedures.. We will review and evaluate key components such as:
  • Anti-corruption (merger and acquisition) due diligence integration procedures
  • Disciplinary and incentive procedures for violations of policies and procedures
  • Develop a custom tailored CSR/BFC framework and roadmap
  • Evidence that the compliance program is well designed, effectively overseen, custom tailored to the needs, size, structure, and risk profile
  • How is the board/management committed to compliance (the "tone at the top and middle")?
  • Introducing regular anti-corruption risk assessments for continuity, evaluation of the risk profile
  • Monitoring and audit and evaluation processes
  • Policies and procedures covering certain risky BFC/CSR activities
  • Procedures and practices for third-party compliance and distributor or similar due diligence
  • Provide country-by-country BA/FCPA reinforcement training tailored to geography- and business-specific risks
  • Questions for audit/risk committees to consider
  • Review of the whistleblower reporting systems Training protocols and e-learning
  • The attention to detail of the full anti-corruption risk assessment program
  • The overall assurance of the BFC/CSR compliance framework

Copenhagen Compliance® provides advisory and consultancy to upgrade your anti-corruption and CSR efforts, policies, procedures and processes so that they are non-compromising, relevant, material and direct. We can improve the insights, best practice and provide you with the need to know information, to raise awareness of bribery and corruption issues and provide guidance on the business role and leadership by the officers in combating and preventing bribery and corruption. The above methodology is part of our CERP advisory. For details see:

The EU directive applies to companies with more than 500 employees and either a balance of 20 million € or net revenues of 40 million €. A total of approx. 16,000 businesses at EU level will be affected by this EU directive.