This article outlines seven must-have characteristics of a sustainable corporate compliance framework.


Establishing a compliance programme in an organisation which is proud of its corporate culture and values, and has not yet had to confront a major allegation of misconduct, can be an uphill battle. Confidence is a good thing, complacency or even arrogance certainly is not and often there is only a fine line in between.

Assuming the organisation presents a perfect world where compliance on all levels and at all times is self-evident is simply unrealistic. With today’s corporate and operational complexities, commercial pressures and manyfold challenges, non-compliance risks are the harsh reality, also in companies with a historically strong ethical culture. Even if nobody within the organisation is deliberately breaking the rules, misconduct can also result from unawareness or misinterpretation. Setting out the rules, explaining and enforcing them are essential elements of corporate governance. Thinking otherwise and considering proactive promotion of compliance in the organisation an unnecessary burden is misjudging reality and leads to complacency. The latter is both naive and risky and sets in motion a vicious circle. The false sense of security weakensdefences and the lack of prevention and detection leads to an increase of violations in an environment that is unprepared to address them effectively.

Oct-Dec 2017 Issue

Unternehmensgruppe Theo Müller S.e.c.s.