Compliance

We are convinced that the best way to create and implement an effective compliance system is to first determine the business needs, identify the processes, and recognise the legal and compliance risks of an organisation. This makes it possible to identify specific risk areas relevant to the organisation that need to be addressed in internal procedures. Therefore, as part of our advice, we:

• map risks;
• analyse processes; and
• select the best compliance tools.

We tailor all of our proposed solutions to the specific characteristics of the client and the industry in which it operates. The aim of our advice is not only to protect the organisation from legal, reputational, and business risks, but also to optimise processes and enable safe and efficient business operations. As part of our support, we:

• analyse and develop comprehensive compliance systems;
• prepare compliance procedures that, on one hand, adequately protect the company, management and employees, and on the other hand are easy to remember and apply; and
• train the organisation’s management and employees in order to create the broadest possible awareness of compliance.

We conduct internal investigations as part of internal audits. We provide services in the areas of:

• prevention – we perform internal electronic communication audits and supplier audits, acting both to detect potential irregularities and risks, but also to assess and improve the overall quality of internal employee communications; and
• intervention – we carry out comprehensive investigative audits in response to identified or potential fraud cases. We verify internal documentation, audit electronic communications, interview employees and search for links between entities based on open sources of information (open-source intelligence, OSINT).

Our advice helps to detect irregularities, assess their extent, understand their impact, take effective corrective actions (including, potentially, process legal action), mitigate their risk to the organisation, and detect their sources and prevent their occurrence in the future.

We implement effective whistleblower protection systems. We build local reporting channels and analyse scenarios and solutions for corporate whistleblowing systems. We prepare the relevant documentation and train employees and those responsible for compliance systems and management teams in this regard.

We are engaged by our clients to assist in handling whistleblower reports. Our advice also includes the outsourcing of the receipt of reports. We help to plan and implement appropriate follow-up and corrective actions.

We are also a partner of the Whistlelink tool – a professional and recognised platform for whistleblower intake reports and report management.

We verify internal procedures and processes to confirm their compliance with the law and the three ISO compliance standards in the area of compliance:

• compliance management systems (ISO 37301);
• anti-bribery management systems (ISO 37001); and
• whistleblowing management systems (ISO 37002)​.

We adapt the company’s internal documentation and the way the company is organised to meet the requirements of each standard. We carry out complex projects for the implementation of three-in-one standards, and actively support organisations in certification processes.

Verification of counterparties in the supply chain is an important part of our advice:

• we propose solutions that help mitigate risks for the future – taking into account the geographical scope of our clients’ operations and the most up-to-date market benchmarks;
• we have experience in analysing Polish, European and international sanction regimes;
• we prepare counterparty verification procedures taking into account the requirements of sanction regimes, AML/CFT, the Corporate Sustainability Due Diligence Directive (the “CSDDD”) and other legal requirements; and
• we assist obliged institutions in complying with their AML/CFT obligations.

Legal Design is an innovative project in which we transform legal documents in accordance with legal design methodology. We use simple, accessible language (plain language) and thoughtful, visualised graphics. The result of our work is the creation of a tailored, simple and comprehensible message, which at the same time complies with the law. Research results show that the use of Legal Design has a positive impact on the trust of employees and contractors in the organisation and the assimilation of content contained in documents such as internal procedures or contracts with contractors.

Our work includes:

• assistance in the selection of documents for the project;
• analysis of pre- and post-transformation documents using the Logios analysis tool;
• creation and agreement on the project plan (objectives, rules, timetable, KPIs);
• document transformation (language, law, graphics); and
• verification of regulatory compliance (Polish and EU law).

We advise in the area of sustainability (ESG) reporting with a particular focus on the aspect of governance.

In particular, we assist in the development of the implementation of appropriate mechanisms and processes specifically for those aspects of ESG related to the compliance of their activities with applicable laws and corporate governance.

Within the framework of the ESRS G1 standard, we assist with the implementation and disclosure of the following issues related to business conduct:

• business ethics and corporate culture;
• anti-corruption and anti-bribery;
• protection of whistleblowers;
• governance and quality of supplier relations; and
• lobbying activities.