“A car can only drive at high speed safely, if it has reliable brakes.”

Sound and ethical business operations are generally perceived as crucial for the sustainability of an institutions’ performance. Adequate checks and balances ensure that risks are effectively identified, assessed and managed.Although we advocate the 3 Lines of Defense structure, we highly value a  practical approach, acknowledging that for smaller sized institutions it may prove disproportionate. In such cases we are experienced to advise on less complex organization structures, whilst still including sound checks and balances. ‘Overcompliance’ should be avoided, which calls for a strong focus on the core compliance requirements and related governance consequences. Strong governance strengthens an appropriate internal compliance program, in line with your organizational needs.

We can support you in the development of your internal compliance function and governance related requirements, such as:

  • (Corporate) governance
  • Compliance charter and framework
  • Tailoring your 3 Lines of Defence model
  • Development of a Code of Conduct
  • Compliance chart: organization-specific translation of applicable laws, regulations and industry standards
  • Integrity risk assessment (Personal, organizational, relational and market conduct related)
  • Risk based compliance policies, minimum standards and guidances
  • Risk based compliance policies and procedures
  • Input requirements for software applications

Behaviour and culture

 Integrity is not a core value, it is a license to operate.”

The people in your organization drive your company results. Even when everything seems OK in terms of commercial performance, risks related to behaviour and culture can already be visible. Behaviour can be a predictive indicator with respect to future (financial) developments, whereby early intervention may prevent future problems. Major incidents in the financial sector have proven that the root causes behind such incidents are often behaviour or culture driven.

Good behaviour and culture have been on top of the regulatory agenda and is a prominent feature for the Board and Senior Managers at firms across different industries. It has been confirmed that hard controls (such as policies, procedures and monitoring systems) will only be effective in combination with soft controls. Root cause analyses have demonstrated that culture does not always support compliance to those policies and procedures. Compliance is only sustainable if it is embedded in the culture of the organization and the behaviour of its staff.

"Compliance with laws and regulations is not a strategic objective, but rather a minimum requirement. Compliance is moreover meeting stakeholders’ expectations and thereby protecting a company’s reputation."

License to operate

Your business operations require a tailor made compliance framework. The preparations for new license applications are time consuming and require special expertise. We can support you with license applications and are able to translate legal  requirements, as laid down in laws and regulations, into practical compliance obligations. A framework of adequate integrity risk analyses will be set-up, with risk based controls, such as policies, procedures and other control measures that are reasonable in relation to the nature and size of your institution. We are focussed on preventing both ‘undercompliance’ and ‘overcompliance’. Or, in other words, ”More where needed, less where possible”.

Would you like to know how Governance, Risk & Compliance can help your business? Please contact our advisors:

Herman Annink
T +31(0)20 653 36 66
E [email protected]    
Jaap van Dijk
T +31(0)20 653 36 66
E [email protected]
Songül Balaban
T +31(0)20 653 36 66
E [email protected]