Day 1 - Wednesday, January 29, 2020

7:15
Registration & Welcome Coffee
8:00
Opening Remarks from the Co-Chairs
8:15

THINK TANK: ANTI-CORRUPTION COMPLIANCE AND SUSTAINABILITY

How Companies are Meeting New Compliance Expectations of Regulators, Enforcers, Investors and the Civil Society
9:15

KEYNOTE AND Q&A – THE YEAR IN REVIEW

Anti-Corruption Enforcement Priorities and the Impact on Industry in the Nordics Region: Penalty Trends, Disclosure, Cooperation, and Multi- Jurisdictional Coordination
10:00
Morning Networking Break
10:30

CORPORATE COMPLIANCE PROGRAMMES #1

Evaluating and Defending Corporate Compliance Programme to the Agencies Post-DoJ Guidance
11:30

INTERNAL INVESTIGATIONS

Strategies for Structuring, Conducting and Managing the Costs of Local and Multi-Jurisdictional Investigations
12:30
Networking Luncheon
1:45
KEYNOTE ADDRESS AND Q&A
2:30

COUNTRY SNAPSHOT # 1 CHINA

What Industry Needs to Know about the Local Bribery Corruption Crackdown: New, Evolving Standards and Trends
3:15
Afternoon Networking Break
3:45
COMPLIANCE ROUNDTABLES & EXCHANGES
4:30

AUDIENCE POLLING

Resolving Compliance Dilemmas and Potential Conflicts of Interest
5:30
Conference Adjourns

Day 2 - Thursday, January 30, 2020

7:15
Registration & Welcome Coffee
8:00
Opening Remarks from the Co-Chairs
8:15

SPECIAL REMARKS

The UK Bribery Act Key Enforcement Takeaways from the Last 12 Months
9:00
Anti-money Laundering Risks: Best Practices for Detecting Sensitive Areas, Weaknesses and Strengthening Internal Controls
9:45

AUDIENCE POLLING

Operationalising Your Compliance Programme: Dovetailing Your Program, Data Governance and Reporting with the Overall Business Strategy
10:45
Morning Networking Break
11:15

DEFENCE COUNSEL WAR STORIES

Structuring and Managing the Costs of Multi-Jurisdictional Investigations
12:15

COUNTRY SNAPSHOT # 2 RUSSIA SANCTIONS

How to Leverage the Tools in Your Compliance Programme to Manage Sanctions, Trade and More Geopolitical Risks
12:45
Networking Luncheon
1:45
The Working Environment Act Chapter 2 A on Whistleblowing: How Industry is Changing Reporting Systems to Reduce Enforcement Risks
2:45
COMPLIANCE ROUNDTABLES & EXCHANGES
3:45
Afternoon Networking Break
4:15

HYPOTHETICAL EXERCISES

What Would You Do If… How to Resolve Gifts & Hospitality Dilemmas on the Ground
5:00
Conference Ends

Day 1 - Wednesday, January 29, 2020

7:15
Registration & Welcome Coffee
8:00
Opening Remarks from the Co-Chairs
8:15

THINK TANK: ANTI-CORRUPTION COMPLIANCE AND SUSTAINABILITY

How Companies are Meeting New Compliance Expectations of Regulators, Enforcers, Investors and the Civil Society

  • Sustainability and compliance strategic cornerstones in the Nordics
  • What are the drivers of sustainability “requirements”?
  • How the ongoing AML monitoring failure in the banking sector is affecting compliance budget
  • The tools available to maintain an acceptable standard of compliance – what companies are using for reporting?

9:15

KEYNOTE AND Q&A – THE YEAR IN REVIEW

Anti-Corruption Enforcement Priorities and the Impact on Industry in the Nordics Region: Penalty Trends, Disclosure, Cooperation, and Multi- Jurisdictional Coordination

  • The year in review – What the past tells about the future
  • Initiatives from the Nordic Council of Ministers in detecting corruption schemes in the region
  • Global investigations and international cooperation
  • Guidelines for an effective detection of economic crimes
  • Recent developments on addressing corruption in relation to public procurement
  • International privilege issues affecting cross- border investigations

10:00
Morning Networking Break
10:30

CORPORATE COMPLIANCE PROGRAMMES #1

Evaluating and Defending Corporate Compliance Programme to the Agencies Post-DoJ Guidance

This new session will navigate how to prepare for meetings with enforcement agencies and to walk them through your programme. Expert speakers discuss what the agencies are looking for with respect to key programme elements and improvements.

Benefit from an opportunity to hear from seasoned practitioners with extensive first-hand experience and ask them your questions. Amid new, evolving compliance and enforcement priorities such as, the DOJ Guidance on the evaluation of corporate compliance programmes, take away important lessons learned and helpful insights for your compliance efforts.

11:30

INTERNAL INVESTIGATIONS

Strategies for Structuring, Conducting and Managing the Costs of Local and Multi-Jurisdictional Investigations

  • How to assemble the team, determine the scope and engage different departments while ensuring that there is independence in the process
  • What should be the role of the compliance officer in an internal investigation?
  • Cultural considerations and practical interview techniques to ensure you get the information you are seeking in the jurisdiction where the facts took place
  • How to deal with inconclusive findings and avoid any perceptions of “an unsatisfactory” investigation
  • How to communicate with the Nordics authorities regarding a potential violation – What protections are provided to the company?
  • Determining how much you need to spend and how to control the risk of rising costs
  • When to stop: How to know when to conclude the investigation
  • Why some internal investigations do not detect the wrongdoing?

12:30
Networking Luncheon
1:45
KEYNOTE ADDRESS AND Q&A
2:30

COUNTRY SNAPSHOT # 1 CHINA

What Industry Needs to Know about the Local Bribery Corruption Crackdown: New, Evolving Standards and Trends

New for this year, industry experts will discuss the practical realities of operating in China today and beyond, and the latest anti-corruption initiatives and the enforcement landscape. In addition to key updates, speakers will discuss the country- specific challenges affecting risk mitigation.

3:15
Afternoon Networking Break
3:45
COMPLIANCE ROUNDTABLES & EXCHANGES

Select a roundtable and join the discussion, exchange views, debate questions and share experiences around current industry challenges.


# 1 HUMAN RIGHTS & CORRUPTION RISKS:

How Ethics-Based Compliance Systems Drive a Solid Culture and Add Value

  • How do human rights and corruption risks connect and what is in it for organisations?
  • What are the drivers to push companies to assess compliance with human rights?
  • 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

#2 GDPR:

When is Your Organisation at Risk: Processing, Accessing, Transferring, Retaining and Preserving Personal Data

The group will reflect on recent GDPR enforcement actions across different EU Member states with a focus on practical takeaways. Four major cases include:

  • Google vs. The French Data Regulator (CNIL)
  • Centro Hospitalar Barreiro Montijo vs. The Portuguese Data Protection Authority or DPA (CNPD)
  • Knuddels.de vs. The State Commissioner for Data Protection and Freedom of Information Baden-Wuerttemberg (LfDI) in Germany
  • The Austrian DPA (DSB) vs. an Unnamed Limited Liability Company

4:30

AUDIENCE POLLING

Resolving Compliance Dilemmas and Potential Conflicts of Interest

At this unique session, experts will discuss their approaches to navigating grey areas. Topics to be covered include code of conduct breaches, business relationships with SOEs, government officials during public tender processes, former government official, an employee’s family member owning the supplier, and hiring former or retired government officials. The panel will include a special focus on relevant jurisprudence about recent cases.

5:30
Conference Adjourns

Day 2 - Thursday, January 30, 2020

7:15
Registration & Welcome Coffee
8:00
Opening Remarks from the Co-Chairs
8:15

SPECIAL REMARKS

The UK Bribery Act Key Enforcement Takeaways from the Last 12 Months

The most impactful developments over the last twelve months, the changing enforcement landscape, and their effects on corporate compliance efforts moving forward.

  • What recent investigations and prosecutions have revealed about new risks and weak spots compromising banks’ internal control systems
  • What are the common errors around onboarding clients, and/or monitoring accounts and ongoing transactions?
  • How corporate vehicles, non-disclosed schemes or hidden structures can become illegal and risky
  • Cooperation among anti-money laundering and anti-corruption law enforcement agencies globally

9:00
Anti-money Laundering Risks: Best Practices for Detecting Sensitive Areas, Weaknesses and Strengthening Internal Controls
9:45

AUDIENCE POLLING

Operationalising Your Compliance Programme: Dovetailing Your Program, Data Governance and Reporting with the Overall Business Strategy

  • How to meet prosecutors’ expectation of companies to operationalise your compliance programme
  • Developing a sustainable strategy to assign clear responsibilities and accountability to demonstrate compliance
  • How to leverage existing compliance systems and processes, and upgrade them to generate data and flag suspicious transactions
  • Updating protocols for payments, third parties, gifts, travel, and entertainment, charitable and political contributions
  • The ROI of Data analytics, AI and other innovation
  • Developing “Ethics Ambassadors” for your organisation
  • Training officers, directors, employees, agents and business partners
  • Addressing specific cultural nuances when localising your new strategy

10:45
Morning Networking Break
11:15

DEFENCE COUNSEL WAR STORIES

Structuring and Managing the Costs of Multi-Jurisdictional Investigations

Defence counsel on this panel will give real-world examples of a multi-jurisdictional investigation and how best to manage them in a context where risk factors are multiplying, overlapping and becoming more uncertain:

  • The challenges of coordinating with several authorities: Best practices for communicating with foreign authorities
  • How an agreement in one jurisdiction can affect a company’s activities in other key markets
  • How local laws can restrict the internal investigation and ability to cooperate with the authorities: GDPR, Blocking Statute, employment law, professional secrecy, evidence-gathering, and more
  • When the DPA with the DOJ/SFO and/ or a press release can supply important information for foreign authorities concerning corruption in their respective jurisdictions
  • When multi-jurisdictional investigations for corruption allegations trigger prosecutions for fraud, money laundering and personal data protection violation — and vice versa
  • The impact of asserting legal privilege across jurisdictions
  • How can the risk of a multi-jurisdictional investigation impact your disclosure calculus?

12:15

COUNTRY SNAPSHOT # 2 RUSSIA SANCTIONS

How to Leverage the Tools in Your Compliance Programme to Manage Sanctions, Trade and More Geopolitical Risks

New for this year, industry experts will discuss the impact of Russia sanctions on compliance in the Nordic region. Don’t miss a comprehensive update on important new developments of the past few months, recent actions involving Russia and practical insights on how economic sanctions fit into compliance risks for Nordic multinational companies.

12:45
Networking Luncheon
1:45
The Working Environment Act Chapter 2 A on Whistleblowing: How Industry is Changing Reporting Systems to Reduce Enforcement Risks

  • The scope of the whistleblowing regulations is expanded: Who is now covered?
  • How to handle and process whistleblowing notifications going forward
  • What “censurable conditions” means today and what is the impact on the employee’s notification procedure?
  • How to deal with the right offered to employees to notify internally to supervisory authorities and, externally to the media or the public in general
  • What is regarded as retaliation: An extended and detailed list
  • Setting up multiple channels for employees to report wrongdoing
  • New rules regarding liability in relation to an employee subjected to retaliation: How the culpability of the employer will now be assessed?

2:45
COMPLIANCE ROUNDTABLES & EXCHANGES

Select a roundtable and join the discussion, exchange views, debate questions and share experiences around current industry challenges.


#3 Crisis Management
Post Crisis Management & Compliance Certification – A Monitor’s Perspective

  • Examples of the good, bad and ugly
  • How transparent must the company and its officers be about compliance incidents with employees?
  • Strategic insights for external and internal communication
  • At what point communicating with customers and the authorities about the incident is productive or counterproductive?
  • Concrete examples of how to recover your reputation post-crisis

#4 Compliance Training for Sales Functions
What an Impactful Training Programme Looks Like Now

  • The types of compliance training that are tailored to the specificities of the sales functions
    • Fast employee turnover
    • Incentives and rewards
  • Components of the KPI that maintain the right balance between making deals and remaining compliance
  • Fostering and sustaining a strong ethical sales culture

3:45
Afternoon Networking Break
4:15

HYPOTHETICAL EXERCISES

What Would You Do If… How to Resolve Gifts & Hospitality Dilemmas on the Ground

Take the pulse of the audience on a series of scenarios and discover how they respond to these challenges and ensure that the compliance programme is properly implemented as it evolves to deal with multiple new risks.

The polling results will be shared in real-time and the panel of experts will provide practical comments

  • 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

5:00
Conference Ends

Workshop A – ANTI-CORRUPTION CASE REVIEW: The Extra-Territorial Reach of the FCPA, the UKBA and Recent Expectations of Corporate Compliance Programmes

Jan 28, 2020 8:30am – 12:00pm

What is it about?

At this practical session, expert faculty members will review key principles of the Foreign Corrupt Practices Act “FCPA” and the UK Bribery Act “UKBA” including its extra-territorial application to date. The speakers will then delve into the complexities of key and recent regulatory and enforcement matters toward imparting real-life lessons for industry moving forward. Gain helpful insights on the ins and outs of significant cases, and how to leverage the lessons learned to better enhance your compliance status moving forward.

  • Who is covered by the FCPA and the UKBA?
    • organisations – who qualifies
    • individuals – what categories of persons who are covered by the Act
  • What is the extraterritorial reach of the FCPA and the UKBA today?
  • When the extraterritorial application of the FCPA is challenged – how significant is the Hoskins case?
  • What are the new risks affecting organisations and their employees?
  • Basic elements of the FCPA’s anti bribery provisions
  • Key aspects of the FCPA accounting provisions: Books and records requirements of the FCPA and record keeping and internal controls requirements and standards
  • Permissible and impermissible payments
  • Involvement of third parties and due diligence requirements: agents, consultants and joint venture partners
  • Factors that trigger government investigations under the FCPA and the UKBA
  • A deep dive into key investigations and settlements, and what they reveal about DOJ and SEC expectations today
  • Circumstances have led to declinations, DPAs and NPAs
  • What does “cooperation” mean for the authorities as well as the company under investigation? What are the limits and precautions to take?
  • How to cooperate with authorities in the context of multi-jurisdictional investigations
  • Which areas of your compliance programme need to be improved considering an investigation and how can this be achieved?
  • The significance of DOJ Update on the evaluation of Corporate Compliance Programmes
  • Prosecution of individuals such as the director of compliance: what is the scope and the limits of the director of compliance’s personal liability?

Workshop B – THIRD PARTY AND M&A DUE DILIGENCE PROCESSES: How Much and How Deep Due Diligence is Now Enough to Truly Capture any Risks in Transactions, Private Equity Dealings and Hiring

Jan 28, 2020 1:00pm – 4:40pm

What is it about?

This intensive, practical working group will discuss transactional due diligence a myriad of both business and compliance activities such as third-party vetting and on-boarding, M&As pre-transactions challenges, private equity dealings/investment due diligence, screen and background checks before hiring and many more. In the wake of continued high-profile enforcement actions across the globe, the working group will focus on how to resolve new and evolving due diligence challenges. Ensure that you are up-to-speed on the latest due diligence best practices and pitfalls that can heighten exposure.

  • Determining your risk tolerance and how far to go in conducting pre-transaction due diligence
  • Developing a risk model that stratifies your risk based on third parties-and how to perform due diligence accordingly
  • Key GDPR considerations and constraints to your due diligence process – how to proceed without breaches
  • Detecting issues with the target’s sales practices, business model and third parties
  • When and how much due diligence to perform for an ongoing, existing third-party relationship
  • Understanding the local business environment, customs and practices
  • How to incorporate effective front-end vetting and screening protocols on a third party, a target and a potential employee
  • Red flags to consider in a target’s accounting practices and financial
  • Measuring the consequences of potential undiscovered violations before the deal, knowing the negative impact of “buying an enforcement action”
  • How to ensure enough access and meaningful information before the transactions – what to do if such access is impossible in a high-risk jurisdiction
  • What kind of due diligence can be done to get the “true value” of a target
  • What to do when the due diligence reveals problems pre-transaction:
    • how to evaluate background red flags
    • when red flags can derail or delay a transaction
  • What the decision-making process regarding go ahead or with the transaction looks like?