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Supply chain compliance is emerging as one of the most important aspects of any ESG program. The need to correctly disclose, to selecting suppliers and using appropriate long-term agreements, every business must understand and document the environmental, social and governance aspects of its supply chain to avoid protect itself against fines, regulatory action, and most importantly reputational damage.

Earlier in June this year the European Parliament voted in favour of amendments to the proposal of The EU Corporate Sustainability Due Diligence Directive (CSDDD). With implementation of the bill expected n 2024, it is deemed as a landmark legislation regarding the strengthening of human rights. The CSDDD will require companies to monitor their supply chains for the risk of violations of human and environmental rights.

 

‘Crucially, the version backed by the parliament attempts to address some of the barriers victims face when trying to access justice for harms caused by companies. For example, it will allow courts in EU member states to order a company suspected of causing harm to disclose evidence’. – Amnesty International Policy Advisor on Business and Human Rights, Hannah Storey

 

  • The Norwegian Transparency Act (NTA) came into effect in July 2022. Companies are required to carry out due diligence activities to ensure they are operating responsibly, respecting both human rights and decent working conditions.
    • Examining the purpose and effectiveness of the CSDDD and NTA
    • Consequences and penalties for companies who fail to comply.
    • Determining the differences and implementation between Germany’s Supply Chain Due
    • How to best understand your supply chain?
      • What are the issues in third party suppliers / brokers?
      • Discover issues with high-risk markets.

  • Mapping all direct suppliers and business partners:
    • The importance of Supply Chain mapping to create transparency and visibility to meet legal requirements.

  • Exploring how the ESG supply chain management is at substantial risk and what can be done to mitigate it.

  • Self-reporting measures – what should be done if you discover you have not been compliant within the supply chain.

  • Consequences as getting it wrong in many jurisdictions can result in significant fines and exposure to litigation or regulatory action.

 

ESG Reporting
Third Party and Corruption
ECP

Author:

Fabrizio Camerini

Vice President Ethics & Compliance
Yara International

Fabrizio Camerini

Vice President Ethics & Compliance
Yara International

Author:

Olaf Abel Engh

Senior Legal Counsel, Ethics and Anti-corruption
Equinor

Olaf Abel Engh

Senior Legal Counsel, Ethics and Anti-corruption
Equinor

Author:

Theodor Christensen

Company Owner, (Former Deputy Director Sustainability and ESG at Danish FSA, Head of Sustainability Compliance at Danske Bank)
Rimme

Theodor Christensen

Company Owner, (Former Deputy Director Sustainability and ESG at Danish FSA, Head of Sustainability Compliance at Danske Bank)
Rimme

Author:

Fredrik Svensson

Partner
Mannheimer Swartling

Fredrik Svensson

Partner
Mannheimer Swartling

With the EU Directive on Whistleblowing coming into effect there are stricter requirements regarding the internal whistleblowing reporting channel. Thus, companies should evaluate its internal procedures for handling whistleblowing cases and be prepared to take action within short timeframes in order to maintain compliance.

One of the essential provisions of the Directive is that a whistleblower's identity must be treated as confidential. According to the Directive, the whistleblower's identity shall not be disclosed to persons other than those handling the case.

 

  • Understanding how to protect whistle-blowers.

  • Examining the correct framework in place to meet whistleblowing standards.
  • Post care of whistleblowers

  • How to prosecute an employee without being able to disclose the identity of the whistleblower?

  • In a lot of whistleblowing cases there is only a select few individuals who are aware of the illicit act, therefore any prosecution against individuals will leave the whistleblower exposed – how to strengthen your privacy/compliance framework to mitigate this risk?

  • Internal investigators or law firms to handle whistleblowing procedure.
    • Does it open the company to 3rd party risks?

  • The Whistleblowing directive under the EU and Swedish Act on Whistleblowing
    • How to be compliant with directive?
    • What is the correct system to receive claim and record follow up?
    • What are the incentives for employees to report wrongdoing? Benefits or cons?
Whistleblowing Regulatory Update
ECP

Author:

Harri Spolander

Vice President, Group Compliance Officer
Fortum

Harri Spolander

Vice President, Group Compliance Officer
Fortum

With the ongoing sanctions against Russia and impending sanctions to China. Nordic companies and financial institutions have subsidiaries in those countries or have clients that to. As a result, the clarity of what to expect and how to best prepare themselves due to the varying enforcement of sanctions between each country is of great importance. The US, UK and EU have taken different stances on sanctions in their respective regions. Being able to compare and understand the status of the leading governing in regard to sanctions will help Nordic companies be able to better prepare and mitigate risk to sanctions.

  • Examine how OFAC and European Commission administers and enforces economic and trade sanctions in support of national security and foreign policy objectives.
    • Lessons learned from Russia and how it will affect your business in China.
    • How has nationalisation been used as a response to sanctions?

  • How can banks take better grasp at manage geopolitical risks and proactive identify them?

  • Swedish Bankers Association – The derogation from Article 2 of Regulation (EU) No 269/2014. 
    • What it means? What is a firewall?
    • How this derogation helps national authorities to release certain frozen funds or economic resources belonging to companies?
    • The risk in each national authorities implementing and interpreting the regulation differently?

Global Sanctions & Export Controls Update
ECP

Author:

Marcele Rask

Principal Risk Manager, Financial Crime Risk & Prevention Group
Danske Bank

Marcele has in-depth knowledge of Financial Crime, with a demonstrated history in working with highly complex legal issues, with experience in large-scale national and international forensic investigations including one of the largest scale financial crime investigations in an European Bank  and the bankruptcy review of the European umbrella of an investment bank that effected the financial system at large. At Danske Bank, she was  the key driver for aligning processes in establishing the institution 1st Line Sanctions Risk Management and Advisory. 

Marcele holds a Master in International Human Rights Law and a Specialization in International Trade and Business, along with several professional certifications, including CAMS, ACSS, ICA Diploma Financial Crime Prevention and Sanctions.

Marcele Rask

Principal Risk Manager, Financial Crime Risk & Prevention Group
Danske Bank

Marcele has in-depth knowledge of Financial Crime, with a demonstrated history in working with highly complex legal issues, with experience in large-scale national and international forensic investigations including one of the largest scale financial crime investigations in an European Bank  and the bankruptcy review of the European umbrella of an investment bank that effected the financial system at large. At Danske Bank, she was  the key driver for aligning processes in establishing the institution 1st Line Sanctions Risk Management and Advisory. 

Marcele holds a Master in International Human Rights Law and a Specialization in International Trade and Business, along with several professional certifications, including CAMS, ACSS, ICA Diploma Financial Crime Prevention and Sanctions.

Author:

Snorre Welling

Global Trade Sanctions Director
Carlsberg Group

Snorre Welling

Global Trade Sanctions Director
Carlsberg Group

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