Ethics and Compliance

Doing the right thing in a complex world

Ethical business conduct and a strong culture of compliance are vital to businesses and other organisations in today’s corporate world, and can provide business advantages in their own right. In addition, financial penalties and reputational damage caused by lapses in ethical standards and regulatory breaches are never far from the headlines, and the impact can be long lasting.

We can help you navigate the risk and compliance landscape (including local and global regulatory standards, such as the UK Bribery Act and FCPA), target your resources effectively, and create a strong culture of ethics and compliance throughout your organisation.

Optimising your Ethics & Compliance programme

The compliance demands placed on businesses and other organisations are growing by the day. Regulators expect organisations to put in place and evidence their defence against key risks such as bribery and corruption, sanctions, and other anti-competitive and unethical behaviour. Highly regulated sectors such as financial services, pharmaceutical life sciences and oil and gas face even more challenging and increasingly complex requirements, and all face significant financial, operational and reputational damage if they fail. 

While compliance requirements are complex and time-consuming, resources available to meet them are not limitless. By understanding the weak points in your organisation and the risks you face, you can better target your compliance efforts where they will be most effective. Underpinning all of this is the importance of defining and embedding a strong ethical culture with ethical behaviour to match, to ensure that your people are doing the right thing, for the right reasons.

How we can help

Our Ethics and Compliance team have extensive experience working with clients in a range of industries, both those that are regulated and those that are unregulated. We help to identify and assess the risks our clients face, as well as review the effectiveness of compliance efforts, helping to mitigate threats and protect your reputation. Understanding an organisation’s integrity risk goes hand in hand with this, including whether or how the behaviour of its people reflects the desired ethical standards of the organisation.

Our specialist teams work closely with clients in a range of sectors to review, assess, remediate and design compliance programmes in order to help clients achieve Ethics and Compliance standards that align with their values, and are practical, fit for purpose and effective. We use a combination of desktop reviews, targeted interviews, workshops, site visits, data analysis and innovative technology to gauge employee sentiment and carry out surveys when a large pool of data is needed. Whatever your specific Ethics and Compliance needs, we can help:

Risk assessment

  • Compliance risk assessment - reviewing and assessing the risks you face in key compliance areas and identifying the priority areas for focus .
  • Ethics and integrity risk assessment - assessment of actual behaviour against intended behaviour within an organisation to identify areas at higher risk of unethical behaviour and quantify the gaps, with recommendations for remediation. This could include use of our tool Spotlight, explored in more detail below.
  • Third party risk and compliance procedures - risk assessment, procedure reviews and enhancements on a broad range of third party risk areas.

Framework review

  • Ethics and Compliance framework review - assessing your current compliance framework against industry standards and best practice, identifying any gaps that require work. This could include use of our tool Spotlight, explored in more detail below.

Design, implementation and remediation

  • Design and implementation of an Ethics and Compliance function - drafting the framework, scope and policies and procedures in key ethics and compliance areas to meet desired standards, as well as implementation planning and execution.
  • Compliance process outsourcing - executing aspects of your compliance programme for you, using our specialist teams and delivery centres (for example third party due diligence and sanctions screening). This could include use of our Ethics and Compliance dashboard, explored in more detail below.

Due diligence

  • Third party due diligence - individual deep dive integrity reviews or volume global due diligence programmes.
  • Pre- and post-acquisition E&C due diligence and remediation - risk assessment and gap analysis of acquisition targets and follow up remediation to enhance and integrate compliance programmes.

Ethics and Compliance technologies

The following solutions can support many of the activities described above:

  • Ethics and Compliance dashboard - we often find our clients struggle to make best use of the data that they have, meaning they operate inefficiently or may miss identification of risks at an early stage. We have developed a platform, E&C Visualise, that can be tailored to your business which collates Ethics and Compliance related data from disparate sources and visualises it in one place.
  • Spotlight - how do you know your employees are doing the right thing, even when nobody is looking? Our web enabled tool, Spotlight, quantifies the behavioural risk in an organisation, providing insight into how Ethics and Compliance programmes are perceived and working in practice.

Case studies

Compliance framework review

Our client, a start up in the renewable energy sector, was being acquired by a multinational energy company. As part of the acquisition negotiations, the company was required to undertake a review of its compliance framework, with a gap analysis to ensure it matched the compliance standards of its new parent company in key compliance areas including bribery and corruption. We undertook a document review of existing policies and procedures in key compliance areas, as well as carried out a series of interviews and workshops, and benchmarked these against the framework of its new parent company. We provided the client with a detailed gap analysis report, with a prioritised road map to enable them to meet the required compliance standards and complete the acquisition.

Ethics and Compliance framework review and remediation

Our client, within the building materials sector, had a new CCO who wanted to better understand the function he had taken ownership of. We started by assisting his team in understanding the current programme and any gaps through undertaking document reviews, interviews and workshops, and site visits. We utilised an additional online tool to understand the behavioural risk within the company, receiving results from our survey from a large proportion of tens of thousands of employees targeted. This combined approach enabled us to extrapolate from our more in depth findings, and provide more tailored recommendations against different business groups and geographical regions. We assisted the CCO and his team in developing a strategy to implement these, and providing training and a detailed project plan to the Ethics and Compliance team for key elements. 

Ethics Risk Assessment

We have been working with an NGO in the design and implementation of an Ethics Risk Assessment. The organisation has operations in countries across the globe and with varying activities and risk profiles. Our client, a newly appointed Ethics Director, engaged our team to design a global risk assessment that would assess each country office, taking account of behaviour vs expected standards, and any mitigating controls, in a range of key ethical risk areas. We delivered a toolkit using a technology solution which allows the risk assessment to be delivered consistently from each country office, identifying and mapping ethical risks, as well as providing recommendations for mitigating those risks. 

Contact us

Mark Anderson

Mark Anderson

Supply Chain and Operations Leader, PwC United Kingdom

Tel: +44 (0)7770 921256

Kristen Pisciotta

Kristen Pisciotta

Partner, Investigations and Disputes Leader, PwC United Kingdom

Tel: +44 (0)7738 844852

Amr Mousa

Amr Mousa

Partner, GRC Transformation and Ethics and Compliance Leader, PwC United Kingdom

Tel: +44 (0)7795 952156

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