December 20, 2016
Compliance Champion Spotlight
What is a Compliance Champion? A Compliance Champion is an individual or organization committed to fostering and raising the standards of anti-bribery compliance. TRACE Trends will include posts featuring Compliance Champions from time to time.
We hope you enjoy the following entry from this week’s Compliance Champion, and TRACE Partner Firm!
Today’s guest blog post is written by Ms. Natali Phalén of Setterwalls law firm, TRACE's Partner Firm in Sweden. Natali is a member of Setterwall’s Anti-corruption and Internal Investigations Group and regularly assists clients with policies, procedures, and advice on risk management as well as conducting investigations.
Beginning with FY 2017, Swedish companies of a certain size will be required to include non-financial information in their annual reports, including information on their work against corruption. These new disclosure obligations stem from and will implement EC Directive 2014/95/EU, amending Directive 2013/34/EU as regards disclosure of non-financial and diversity information by certain large undertakings and groups.
Although Sweden’s new rules will largely follow the Directive’s specifications, the Swedish legislature has chosen to impose the enhanced reporting obligations more broadly than the Directive requires. The new requirements will apply to companies meeting at least two of the following criteria: (i) the company has more than 250 employees (instead of 500 as in the Directive); (ii) the company’s balance sheet total exceeds SEK 175m; and (iii) the company has net sales of at least SEK 350m.
It has been estimated that around 1,600 Swedish companies will be subject to this new reporting obligation. Although several companies in Sweden already disclose non-financial information in their annual reports, not all of the companies affected by the new rules currently do so. Even where companies do already disclose non-financial information, it may not yet be sufficient to meet the new disclosure requirements—particularly with respect to information on anti-corruption work.
The new reporting obligation will thus not only require many of these 1,6000 companies to add certain information to their annual reports, but may also prompt deeper reflection on how they address corruption issues. Ideally, this will lead to an increased focus on these issues and a more strategic and efficient anti-corruption work among Swedish companies.
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