compliance & internal investigations

compliance

At Schoenherr we are experienced in providing compliance advice in various industries. We conduct risk analyses of the respective corporate areas and pro-vide support with the implementation of individual, tailor-made compliance programmes, including preventative measures, handling of compliance issues as well as remediating such issues by adapting the compliance systems.

We advise clients on technology solutions to help them run effective programmes (including our own App) and take administrative burdens off the shoulders of compliance teams. We assist clients in complying with obligations under relevant EU directives (such as the whistleblowing directive) and corresponding national laws.

internal investigations

Should violations of compliance rules be investigated, we offer solutions tailored to the issue at stake and the industry concerned. We have significant experience in investigating all corporate crimes, violations of anti-trust rules, confidential information leaks, tax evasion and breach of legal duties.

Over the past few years we have conducted (internal) investigations in the following sectors: financial services, healthcare & life sciences, manufacturing, construction, and oil & gas.

our services

compliance

• designing compliance management systems, including guidelines, codes of ethics, work instructions, class-room trainings, certifications and documentation
• assisting in the introduction and operation of whistleblowing hotlines
• auditing and keeping compliance management systems up-to-date and responsive to actual business risks
• technical tools and smartphone application to assist in the running of a compliance management system.

supply chain compliance

• due diligence policy development: We help our clients integrate a comprehensive due diligence policy that aligns with the requirements of supply chain laws and reflects the company's values and commitments. We also develop a code of conduct for clients and their business partners that sets out the standards and expectations for responsible business conduct.
• creating new or updating existing compliance management systems: We assist clients in drawing up new compliance management systems as well as in implementing a specific due diligence policy into existing compliance management systems effectively and efficiently.
• identification and assessment of adverse impacts: We help clients map their operations and conduct in-depth assessments to identify potential and actual adverse impacts on human rights and the environment that a company may cause, contribute to, or be directly linked to through its operations, products, services or business relationships. Our services include prioritisation strategies based on the severity and likelihood of the impacts.
• prevention and mitigation plans: We support our clients in developing and implementing prevention and mitigation plans for potential adverse impacts. We help them seek contractual assurances from direct business partners, make necessary investments, and provide targeted support for business partners of in-scope companies.
• remediation plans: We assist our clients in developing corrective action plans to bring actual adverse impacts to an end or minimise their extent. We help them seek contractual assurances from indirect business partners and provide remediation for actual adverse impacts.
• stakeholder engagement: We offer our expertise in carrying out meaningful engagement with stakeholders, including employees, trade unions and civil society organisations. We help them provide relevant information, conduct consultations and address barriers to engagement.
• complaints procedure and notification mechanism: We help our clients establish a complaints procedure and notification mechanism, allowing affected persons and organisations to submit complaints regarding actual or potential adverse impacts.
• monitoring and reporting: We implement systems to monitor the effectiveness of our clients' due diligence measures. We assist companies in preparing and publishing the annual due diligence statement, which needs to include information on a company's due diligence policy, risk assessment, action plans, remediation, stakeholder engagement and monitoring, as well as on any challenges or difficulties they face in implementing supply chain obligations.
• investigation: We support and represent clients in case of investigations led by supervisory authorities. Our experts have in-depth experience in handling public enforcement litigation.

internal investigations

• planning and execution of internal investigations, including forging amnesty programmes to help with the gathering of information.
• advising on next steps based on the results of an investigation, including internal disciplinary measures, possible external reporting and remediation.
• assisting with communication and PR, both internally and externally
• asset recovery, enforcement of receivables and damage claims, as well as defence before courts and authorities.