Taking an integrated approach to compliance 

As global compliance requirements expand, recent legislation such as the Corporate Sustainability Reporting Directive (2023) and the Corporate Sustainability Due Diligence Directive (2024) compel companies to focus on human rights and environmental impacts. However, corruption risks remain an important compliance consideration, particularly in high-risk sectors. Notably, while not always explicitly stated, the CSRD also requires companies to address their anti-bribery and corruption (ABC) programme alongside their environmental and human rights impacts. 

Recognising the interconnectedness of anti-bribery and corruption (ABC), human rights and environmental issues allows organisations to adopt a holistic and progressive approach to compliance. This perspective not only strengthens ethical practices across all areas but also enhances the effectiveness of each individual compliance measure and ensures that efforts are not duplicated from an operational point of view, particularly for due diligence processes. 

By aligning ABC initiatives with sustainability efforts, companies can build a compliance framework that not only mitigates legal risks but also strengthens long-term resilience. Such an approach enables businesses to respond proactively to emerging regulatory demands and to manage reputational risks effectively. Integrating anti-corruption with human rights and environmental considerations demonstrates a company’s commitment to ethical governance, which in turn helps to maintain the trust of investors, stakeholders and the public. It also helps to position the company as a leader in responsible business practices. 

The Interconnectedness of compliance issues 

Rather than viewing these compliance areas as separate or competing priorities, organisations should recognise the interconnectedness of these compliance areas: strong ABC controls can reinforce human rights and environmental programmes by safeguarding people and resources and ensuring ethical practices are upheld. Corruption often facilitates abuses in other areas. For example, instances across various sectors have demonstrated how bribery can lead to environmental degradation and human rights abuses, with illicit payments undermining community welfare and contributing to the erosion of ecosystems. Whether in manufacturing, construction, agriculture or extractives, corrupt practices can bypass crucial environmental protections and exploit vulnerable populations. 

Key steps to developing an integrated compliance approach

Through our work helping companies build and embed effective ethics and compliance programmes, both nationally and internationally, we have identified the areas where an integrated approach can be best applied. This ensures that the risks are considered holistically from all relevant perspectives, and the required management practices streamlined across the organisation. 

• Cross-functional risk committees: Create committees that bring together environmental, human rights and compliance leaders to regularly discuss emerging risks and opportunities. This will allow for shared accountability and for the team to view risk patterns holistically, aligning mitigating actions across the business. 

• Integrated due diligence on partners and suppliers: Evaluate third parties on a range of compliance topics, including human rights, environment and anti-corruption performance. By gathering data on these topics together, the evaluation of actual human rights and environmental impacts can be more robust, helping to effectively identify upstream and downstream risks from third parties. 

• Integrated risk assessments: Conduct risk assessments that consider the interplay between environmental impact, human rights obligations and corruption risks.  

• Comprehensive training programmes: Instead of siloed training, develop comprehensive programmes that emphasise how corruption, environmental harm and human rights abuses are interlinked.  

• Data sharing and reporting: Develop reporting structures that require teams to share relevant data across departments. A shared dashboard, for example, could help track how environmental risks influence human rights impacts or how anti-corruption measures could mitigate other risks, enhancing overall transparency and oversight. 

Conclusion 

This integrated approach to compliance is increasingly important for companies committed to ethical governance and sustainability. By recognising the interconnectedness of corruption, human rights and environmental risks, organisations can build robust compliance frameworks that go beyond legal requirements and allow organisations to meet their sustainability goals. This integrated strategy not only addresses legal and reputational risks but also reinforces a culture of integrity across all facets of an organisation. 

From our work, we know that taking an integrated approach to managing compliance risks ensures a more holistic approach to risk management and ensures that risks to the business as a whole are considered rather than viewed through a narrow lens or from a single-issue perspective.