Opening Remarks from the Co-Chairs

Erica Wikman
Vice President, Compliance and Corporate Integrity
Autoliv (Sweden)

Jeppe Kromann Haarsted
Group Compliance Manager
FLSmidth (Denmark)

Fabrizio Camerini
Director, Ethics & Compliance
Yara International (Norway)

“WAR STORIES” AND GLOBAL COMPLIANCE STRATEGY SESSION (AUDIENCE POLLING)

Compliance Decision-Makers in the Nordics Share Best Practices and Priorities in the Wake of the Global Pandemic, Geopolitical Shifts, Anti-Corruption, ESG, AML and More

Camilla Orko
Vice President, Chief Compliance Officer
Cargotec (Finland)

Philippe Vollot
Chief Compliance Officer and Member of the Executive Board
Danske Bank (Denmark)

Ute A. Joas Quinn
Group General Counsel, Corporate Secretary & Chief Compliance Officer
DNO ASA (Norway)

Moderator:

Tom Best
Partner
Paul Hastings LLP (USA)

Leading anti-corruption compliance experts will gather for this panel to reflect on the most important takeaways, hidden lessons and war stories on navigating unprecedented times. Topics will include:

• Anti-Corruption compliance in 2021: What has changed over the previous year?
• Concrete examples of prioritizing and ranking tasks and to-do’s in a compliance function today: Choosing what tasks to perform daily vs. weekly vs. monthly
• Remote working and employee training to ensure “virtual” compliance
• Ensuring continued compliance with fewer employees due to furloughs and
• Mitigating the increased risk of fraud and misuse of government funds and tax money to prop up struggling businesses
• Behavioral compliance: Employee monitoring and training
• Monitoring teams on the frontlines: Sales and marketing
• Compliance amid budgetary pressures
• Obtaining senior-level buy-in and commitment to compliance
• Due diligence vs. monitoring: The most common dilemmas, and how to tackle and solve them

KEYNOTE INTERVIEW WITH BRAZIL’S PUBLIC PROSECUTOR’S OFFICE

Eduardo El Hage
Federal Public Prosecutor
Ministério Público Federal, MPF (Brazil)

Moderator:

Karla Lini Maeji
Partner
TozziniFreire Advogados (Brazil)

• The enforcer’s view: Understanding, from the enforcement authority’s point of view, a recalibration in Brazilian enforcement priorities, especially as regards Nordic and other foreign companies doing business in Brazil
• International cooperation: How Brazilian authorities are cooperating with Nordic and other foreign enforcement agencies, anticipated trends for the near future, and how this could impact Nordic companies’ compliance strategies
• Regional approach: With Nordic companies having been implicated in enforcement actions in Brazil in recent years, this part of the discussion will address cultural aspects, analysed from a Brazilian standpoint, that can help understand those past occurrences and prevent similar issues in the future

1:1 Networking Break

COMPLYING WITH THE EU’S WHISTLEBLOWER LAW IN PRACTICE (AUDIENCE POLLING)

How Industry is Strengthening a “Speak-Up” Culture One Year Before the Deadline for National Implementation

Erica Wikman
Vice President, Compliance and Corporate Integrity
Autoliv (Sweden)

Linda Carlsson
Compliance Officer
ASSA ABLOY Entrance Systems (Sweden)

Martin Lønstrup
Vice President and Head of Compliance
Sandvik

• Creating an “open-minded” company culture where speaking up is considered a good deed
• The next level of openness: Complying with the law vs. encouraging employees to actually speak up
• The importance of data privacy and disclosure policies in protecting whistleblowers
• Testimonies from companies who have been actively working towards implementing EU guidelines throughout their organization
• Burden of proof: Distinguishing between usable evidence and red flags
• How to reconcile the need for an effective whistleblowing infrastructure with ever tightening data privacy laws

SPECIAL INTERVIEW

What It Takes to Upgrade Your Global Compliance Program in the Wake of a Settlement

Laurie Waddy
Chief Compliance Officer
Ericsson (Sweden)
(Former Head Group Compliance at Bilfinger SE)

William Jacobson
Partner
Allen & Overy (USA)
(Former Compliance Monitor for Braskem)

• What went wrong, what happened, and how were the compliance shortfalls addressed?
• Who was involved (e.g., C-suite, top management, third parties, other business partners)
• Cooperation with international enforcement authorities: The most important lessons

Compliance Insights from the Nordic Business Ethics Initiative

Niina Ratsula
Co-Founder
Nordic Business Ethics Initiative

Conference Day 1 Adjourns

EXCLUSIVE IN-HOUSE COMPLIANCE ROUNDTABLE: “OFF-THE-RECORD”

Stephen Storey
Chief Ethics & Compliance Officer
Rio Tinto (United Kingdom)

Moderator:

Satnam Tumani
Partner
Kirkland & Ellis LLP (United Kingdom)

Designed as a closed-door, smaller-group discussion on highly complex challenges, participants will benefit from meaningful opportunities to exchange more “war stories” in the wake of Covid-19 and best practices. (All interested parties will be pre-qualified prior to registration. There is no additional fee for this session.)

Opening Remarks from the Co-Chairs

HUMAN RIGHTS, COLLECTIVE ACTION, ESG & REPUTATIONAL CONSIDERATIONS

Special Considerations for Evolving Compliance Systems, Policies and Protocols

Fabrizio Camerini
Director, Ethics & Compliance
Yara International (Norway)

Casper Venbjerg Hansen
Director, Corporate Compliance Officer
Ambu A/S (Denmark)

Francesca Manta
Manager, Human Rights
BSR (Denmark)

Jonathan C. Drimmer
Partner
Paul Hastings LLP (USA)

• The oft-overlooked link between human rights and corruption: Why it is so important
• “What’s in it for multinationals” who explicitly inscribe human rights in their compliance programme?
• The importance of the UK’s Modern Slavery Act
• Will multinational companies need to make changes to comply with the EU Commission’s forthcoming “Mandatory Human Rights Due Diligence Legislation”?
• How companies should put transparency and accountability at the forefront of their operating principles
• How existing compliance programme and systems should be upgraded to incorporate ethics and human rights
• How to uphold basic human rights standards when partnering with state-owned entities that does not adhere to the same anti-corruption compliance standards?
• The contribution of collective actions initiatives in furthering compliance across industries to share data and screening systems, blacklists, due diligence reports, and conduct joint investigations

GENERAL COUNSEL INTERVIEW

Caroline Pontoppidan
Senior Vice President, General Counsel and Head of Corporate Affairs
A.P. Moller – Maersk (Denmark)

Dylan G. Moses
Partner
K&L Gates (United Kingdom)

Bjørn Raasteen
Group General Counsel, Senior Vice President - Group Legal
ISS World Services A/S (Denmark)

Lending additional context to the conference and, in particular, in the 2020 wake of the Covid-19 pandemic, participants will benefit from strategic insights at the highest level on the most pressing risks of the present and moving forward.

1:1 Networking Break

SPECIAL INTERVIEW WITH THE U.S. DOJ AND SECURITIES AND EXCHANGE COMMISSION

What Industry in the Nordics Should Know About U.S. Enforcement Priorities, Compliance Expectations, and Cooperation with Other International Agencies

Christopher J. Cestaro
Chief, FCPA Unit, Fraud Section, Criminal Division
U.S. Department of Justice

Robert I. Dodge
Assistant Director, FCPA Unit
U.S. Securities and Exchange Commission

James M. Koukios
Partner
Morrison & Foerster LLP (USA)

As compliance officers worldwide navigate these unprecedented times together, ACI is pleased to offer our esteemed delegates an opportunity to virtually connect with key officials of some of the most globally-active enforcement agencies – to discuss their respective approach to ensuring continued anti-corruption compliance and enforcement, as well as any impact on their activities and priorities due to covid-19. Submit your questions prior to or live throughout the session. All questions will be pre-screened and shared with the faculty on a strictly anonymous basis.

CROSS-BORDER ENFORCEMENT: INDIVIDUAL AND CORPORATE PROSECUTIONS AND SETTLEMENTS IN THE NORDICS

Defense Counsel in the Most High-Profile Cases Discuss the Lesser Known Risks and Takeaways for Multinationals and In-House Professionals in the Region

Anne Hukkelaas Gaustad
Partner
Hughes Hubbard & Reed LLP (France)

Camilla de Silva
Partner
Simmons & Simmons LLP (United Kingdom)
(Former Co-Head of Fraud and Corruption at U.K. Serious Fraud Office, SFO)

• Practical implications of the latest updates (June 1) to the DOJ’s compliance guidance manual
• What the DOJ means specifically by stating that “compliance programmes need to be data-driven” and emphasizing the importance of “middle management”
• Enforcement in the Nordics: Drawing conclusions from the latest cases involving Nordic multinationals
• How regulators cooperate when they are unable to meet in person amid covid
• How joint documents reviews work remotely?
• In what way global enforcement agencies are adjusting to the “new normal” when launching new investigations?

COUNTRY BREAKOUTS & IMPACT OF THE LATEST LEGISLATIVE DEVELOPMENTS

Compare and Contrast Your Compliance Approach in Different Jurisdictions with Your Peers in These Closed-Door Sessions

Brazil

Michel Sancovski
Partner
Tauil & Chequer Advogados in association with Mayer Brown (Brazil)

China

Bingna Guo
Partner
White & Case LLP (China)

Russia

Laura M. Brank
Partner
Dechert LLP (Russia)

Conference Day 2 Adjourns

Opening Remarks from the Co-Chairs

DATA PROTECTION AND GDPR: THE OFFICIAL POINT-OF-VIEW

Member State Officials Discuss the EU’s Data Protection Regime and Compliance Expectations

Leonardo Cervera-Navas
Director
EDPS - European Data Protection Supervisor (Belgium)

Olivier Micol
Head of Unit, Data Protection
Directorate-General for Justice and Consumers, European Commission

Elisabeth Jilderyd
International Legal Advisor and Coordinator; International and EU Department
The Swedish Data Protection Authority

Maria Wilhelm
Head of the Europe Office
Office of the State Representative for Data Protection and Freedom of Information in the State of Baden-Württemberg (Germany)

Moderator:

Dr. Andrea Pomana
Lawyer
Debevoise & Plimpton LLP (Germany)

This highly-anticipated panel will feature a lively discussion on the status and achievements of the GDPR in the past two years, the cooperation between the European Data Protection Board and European data protection agencies in enforcing the GDPR in an effective and coherent way across the EU, key takeaways for multinational companies and their compliance programs, as well as the state of international transfers of data following the Schrems II decision of the European Court of Justice.

SPOTLIGHT ON DATA PRIVACY (AUDIENCE POLLING)

What It Looks Like in Practice to Comply with the EU’s and Member States’ Data Protection Legislation – A Discussion Featuring Concrete “How To Do” Examples and Proven Best Practices

Hanne Bay
Group Director, Business Integrity & Compliance & Data Privacy
Ramboll Group (Denmark)

Maria Lock Ryvard
Data Protection Compliance Counsel
Novo Nordisk (Denmark)

Tue Goldschmieding
Partner
Gorrissen Federspiel (Denmark)

• How to keep your privacy compliance program up to date if you already have a proven and well-functioning program in place
• Assessing the implications for data transfers from the EU to the US following the striking down of the US-EU Privacy Shield (the “Schrems II” decision)

1:1 Networking Break

CASE STUDY: INTERNAL INVESTIGATIONS – IN-PERSON AND REMOTE

The Lesser Known Nuances of Privilege, Evidence Gathering, Witness Interviews, and Corporate Communications: Real-World Examples of Successes and Missteps

Jeppe Kromann Haarsted
Group Compliance Manager
FLSmidth (Denmark)

Thomas Markus Etter
Compliance and Corporate Responsibility Director
Hempel A/S (Denmark)

Thomas Skou Roer
Assistant Professor, External Lecturer in Forensic Psychology
University College Copenhagen (Denmark)

Tormod Tingstad
Advokat, Head of Investigations
Gorrissen Federspiel (Denmark)

Gareth Rees QC
Partner
Morrison & Foerster LLP (United Kingdom)

• Communication is everything: How to approach and inform your organization of an investigation into suspicious conduct
• Mapping suppliers, customers and third parties: Tackling the most common objections from business partners to cooperate in an investigation
• The role of forensic data analysis and AI in identifying which information is most germane to an investigation
• Data privacy considerations: How to resolve the trickiest issues in light of tightened international data protection and data sharing legislation
• The scope of privilege across the Nordics relating to interviews during an internal investigation, notes and memoranda
• The significance of U.S. v. Connolly in the Nordics region: New considerations for handling internal investigations
• How the increasing use of social media and messaging apps has affected the course of internal investigations
• When multi-jurisdictional bribery enforcement could spark investigations into other crimes, including fraud, money laundering and privacy violations-and vice versa
• The impact of multi-jurisdictional enforcement risks on your decision to disclose or cooperate

SANCTIONS & EXPORT CONTROLS: RUSSIA, IRAN, VENEZUELA, CUBA AND CHINA

How Recent Geopolitical and Legislative Developments Have Intensified Economic Sanctions Compliance Risks

Zia Gheewalla
Group Compliance and Ethics Officer
Electrolux (Sweden)

Brian J. Fleming
Member
Miller & Chevalier Chartered (USA)

Moderator:

Jeffrey Cottle
Partner
Norton Rose Fulbright (United Kingdom)

In light of ramped-up sanctions enforcement activity on behalf of US and UK agencies, this panel will shed light on recently emerged priorities and their interplay with EU rules, with topics including:

• China, Huawei and Hong Kong: New trouble and compliance challenges on the horizon
• Latest changes in Russia secondary sanctions
• Impact of the snapback of Iran sanctions
• Potential blocking statutes in the EU
• How to minimize risk and upgrade your sanctions compliance program
• Potential new sanctions restrictions on Venezuela and North Korea
• Impact of Brexit on sanctions enforcement
• How a multinational company can stay abreast of various sanctions restrictions, and how to coordinate the rules from multiple government agencies efficiently
• Recent trends emerging from OFAC, DOJ and SEC investigations of sanctions violations

SPECIAL AUDIENCE Q&A AND HYPOTHETICAL SCENARIOS (AUDIENCE POLLING)

What Would You Do If…? Resolving Charitable Donations, Gifts, Travel & Hospitality Dilemmas

Elizabeth Wilks-Wood
Vice President Compliance
Carlsberg Group (Denmark)

Andrew Reeves
Counsel
Norton Rose Fulbright LLP (United Kingdom)

Maja de Vibe
Senior Vice President Sustainability, Governance and Compliance (Chief Compliance Officer)
Statkraft (Norway)

During this practical, interactive session, participants will benefit from a worthwhile opportunity to work through some of the most vexing “grey areas” associated with charitable donations, gifts, hospitality and entertainment. With the use of anonymous audience polling, attendees will be able to compare their approaches to handling sensitive, hot button issues. The polling results will be shared in real-time and the panel of experts will provide practical analysis.

• Navigating the line between hospitality vs. a bribe
• Giving, receiving, accepting and refusing gift, hospitality and entertainment:
• Determining your organisation’s boundaries
• How it is communicated to people in locations you are operating in?
• Sponsorship and donation: How to respond to solicitations from customers, suppliers, foreign government officials and more
• Third party vendors: When you need to use vendors to handle your marketing and business developments activities
• Commission payments, petty cash activity and cash advances

Conference Concludes