During the ICC International Week of Integrity initiative dated…
For companies that need a thorough review and upgrade of the ethics & compliance program, DeComplianceMonitor is ‘the place to be’. We help to ensure that supervisors, bankers and the government can rely on the compliance effectiveness.
We build upon extensive experience in governance, legal, risk & compliance management. Our approach enables the company’s management to take the lead, while being supported by a reliable oversight on the risks and effective control measures.
High level guidance
- Expert guidance & tailored support;
- Risk assessment & review in context of corporate risk profile;
- Sound implementation of global standards;
- Progress reports to further upgrade the compliance program.
DeComplianceMonitor is specialized in assessement of corporate ethics & compliance programs to ensure that it can meet with the latest standards of ‘good business practice. Our team has been ‘tried and tested’ in maintaining high level compliance programs and related consultations with stakeholders, to ensure high level of integrity througout the organisation.
Our track record
DeComplianceMonitor has been selected and appointed by the Worldbank to conduct monitorships of Dutch companies with international business activities. We accompany many companies with preventative, self imposed, compliance reviews to strengthen the compliance program, ‘risk based’ and well designed.
Each of us offers the seniority, experience and expertise to assist executive management and supervisory bodies when they are put to the test. This may vary from threats of criminal prosecution, investigations by regulators, or involvement by other stakeholders, including banks and governmental organisations.
Our credentials are available at request.
When should you consider our support:
- When involved in settlement agreements with the Public Prosecution Service;
- To adhere to agreements with foreign public authorities such as the DOJ in the US and/or the UK Serious Fraud Office;
- At initiative of Dutch regulators, including Dutch Central Bank, AFM, ACM, NZa and/or foreign regulators such as the UK Financial Conduct Authority;
- Following recommendations by your external accountant, banks, (national) public authorities, and/or other stakeholders such as the World Bank;
- By way of preventative action, taken by the senior management and/or supervisory body of the company.
The commitment of the executive management to address identified shortcomings is crucial. Our tailored risk analyses help to determine the direction to take – in conformity with relevant laws and regulations, guidelines and standards. The objective, scope and approach of our compliance review are, as much as possible, determined and coordinated in advance. Mutual expectations are thus optimally aligned.
Examples of published Standards and Guidelines:
Good practices on fighting corruption (DNB)
Good practices on Systematic Integrity Risk Assessment (DNB)
Impementation and Certification Scheme for Integrity Management Systems (SIO)
A Resource Guide to the US FCPA (DoJ & SEC)
Evaluation of Corporate Compliance Programs (DoJ)
Guidance on Bribery Act and DPAs (SFO)
Anticorruption Compliance Guide (AFA)
World Bank Group Integrity Compliance Guidelines
OECD standards; ICC guidelines; ISO anti-corruption standards
DeComplianceMonitor offers support by seasoned professionals to perform a comprehensive review of the effectiveness of compliance programs at listed companies, financial institutions, (semi)public organisations, and family-owned companies. Performing such a review may not only be required by regulatory authorities, governments and/or enforcement agencies, it also serves as valid prevention to safeguard sound international business operations for the benefit of all stakeholders.
Michael is founder and Managing Director of DeComplianceMonitor. He has extensive experience in the field of (integrity) risk management, compliance, legal, and governance, providing guidance and advice for a wide range of companies, (semi) governmental organizations, and supervisory authorities. He served as compliance monitor and independent expert on behalf of the World Bank. For several years he was compliance director at ABNAMRO Bank. Michael started his career as a lawyer and corporate legal counsel. Since 2009, he has been self-employed. Michael is author of various book and articles in professional magazines on compliance risk management.
Jan has extensive experience in various industries, including oil and energy, research & technology, aviation and shipbuilding. Amongst others, he was Head of Legal & Corporate Affairs, corporate secretary, HR manager and has developed several ethics & compliance programs. He has considerable knowledge of organizational development and has developed and implemented change and recovery programs in the areas of compliance, integrity, fraud & corruption issues, and business ethics. In addition, he specialises in sanctions & export control programs for internationally operating companies.
Juliëtte is an experienced (integrity) risk management advisor. Juliëtte provides assessments on how organizational culture influences conduct, governance, and risk management. She served as a Head of Integrity Supervision at Dutch Central Bank (DNB) and has lead several supervisory teams in the area of AML/CFT, sanctions, anti-corruption, conflicts of interest, and fraud. Juliëtte is also a trained expert assessor involved in the FATF and provides expert training for organisations in the financial industry and other industry sectors. She worked for @samhoud consultancy from 2020 until October 2023. Juliëtte started her career as a lawyer with Allen & Overy and Houthoff Buruma.
Paul is an experienced international Risk & Compliance Officer, specialized in managing full comprehensive compliance programs in an international business context. Starting his carrier at HBG, Paul worked for Siemens in various (inter)national management functions. Until June 2018, he was a member of the Siemens Global Compliance organization, heading Compliance for The Netherlands and Ukraine. Paul is an active member of various non-governmental institutes for anti-corruption & bribery.
René van den Bosch is an experienced independent legal consultant advising companies on regulatory compliance and related investigations. He was in-house legal counsel at ING for 12 years, advising on regulatory compliance matters and in- and external investigations globally. His role included setting legal strategy, advising senior management as well as engaging with regulators in multiple jurisdictions and working closely with in- and external stakeholders. He also worked as a lawyer in the Investigations and Regulatory Advisory Team at the international law firm Allen & Overy in Amsterdam. He started his career as a financial economic crime investigator at the FIOD and assistant public prosecutor in the corporate fraud team of the Dutch Public Prosecutor’s Office in Amsterdam. René also was one of the founding Board members of the Institute For Financial Crime (IFFC).
Obbe believes that integrity and compliance activities need to be part of business workflows and organized cross-functional to make impact and to avoid bolt-on compliance. Bespoke solutions tied to company purpose and business principles will be supportive to conduct business in in a responsible way and will safeguard company branding and reputation. His experience ranges from general compliance work such as building and implementing a compliance program, risk and crisis management, whistleblowing and investigations, export controls and sanctions, third party reviews and diagnosing bribery risk to specific topics such as responsible sourcing, OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights, operating in volatile environments and ESG-standards. He has a longstanding background in integrity and compliance in listed internationally operating companies in different sectors.
Mirjam Bakker is Chief Compliance Officer at ABNAMRO Bank NV. She has a long ranging background in compliance and risk management, ERM, and corporate counsel positions in global listed companies in multiple sectors. Mirjam also serves on the expert advisory board of the Dutch Centre of Organizational Integrity (COI), and she is the Chair of the Board of ICC the Netherlands. Mirjam has a strong record in leading cultural change and supervision in complex organizational settings.
Jan Karel is a former Group General Counsel/Chief Legal Officer, having served several multinational corporations like Royal Philips, Rabobank, Nuon (now: Vattenfall), AkzoNobel, Dutch Railways, and ABNAMRO. Jan Karel has a long ranging background in governance, ERM, L&C, and government affairs. He has knowledge of design and implementation of governance and compliance structures. Jan Karel also gained experience in the Public Prosector’s Offices.
Muel Kaptein is a Professor in Business Ethics and Integrity Management at the RSM Erasmus University Rotterdam. Since joining Erasmus University in 1991, he has authored eight books and more than 50 peer-reviewed articles. He is also partner at KPMG, where he cofounded the ethics & integrity consulting services in 1996. Muel has a strong record in helping organizations to restore and improve their ethics, integrity and compliance.
Guido brings a solid background in compliance & ethics program management to the table including multiple years of practical experience across various industries in the international business arena. Guido has dealt first hand with external investigations and extensive monitoring in the areas of bribery, corruption, fraud and antitrust. Guido holds a degree in law and a post-academic degree in corporate compliance & integrity management.
For more information, please do not hesitate to contact us.
The DCM Protocol describes our approach in more detail. Interested? Please contact us.