Will EU CSRD significantly affect how you approach anti-corruption compliance?
??EU CSRD & Anti-Corruption Compliance -
Following June’s poll results below, I come back to you on a couple of tips regarding your anti-corruption compliance program…. because YES: CSRD will (significantly) affect your way of approaching anti-corruption compliance:
??CSRD will require you to perform a risk assessment that will have to cover corruption. If you are subject to Sapin II, don’t think your Sapin II risk mapping will be enough:
?? You will need to add double materiality analysis
?? You will have to further develop actual/potential assessment
??You will have to extend your mapping to downstream activities… and the upstream portion of your chain of values…
?? If you are not subject to French Sapin II law, you may want to learn more about the French methodology to convert your anti-corruption risk assessment’s results into a mapping… (a thorough exercise!) especially considering the anticipated influence of the Agence fran?aise anticorruption over the guidelines that will be drafted at EU level to help implement the CS3D by the future Member States agencies.
??On top of being challenged by your financial auditors on anti-corruption compliance and corruption cases, you will now also be challenged by your CSRD auditors if they are different. In particular as you may be incited internally or externally to publish more information as suggested by CSRD.
That’s just a couple of tips for anti-corruption compliance professionals in companies subject to extraterritorial EU CSRD ??.
To the broader population of legal and compliance professionals around the world on 5 specific actions they should perform as lawyers to protect their companies from the tricks of the CSRD, check-out the Replay of our last webinar on this topic: https://lnkd.in/eucw7SUW ???
ART, Legal-Tax-Compliance, Risk Management Director chez HDI GLOBAL SE France
1 个月Très utile