MANAGING THE RISK FOR corporate (mis)conduct

Anna Romberg is a driven anti-corruption, compliance and governance expert. Based on her broad in-house experience from compliance, internal audit, internal controls and risk management she assists global companies on a wide range of assurance related topics through her own business. She has worked with several industries such as banking, energy sector, telecom, manufacturing, medtech, mining and property development.

Anna was responsible for the well recognized Anti-Bribery and Corruption and remediation program at Telia Company as a part of the settlement negotiations with the US DOJ, SEC and Dutch authorities. At Cargotec, a company operating on a global scale and in several high risk industries, she built a framework for Combined Assurance, an organization for Ethics & Compliance, implemented ABC and Third Party management compliance programs as well as managed numerous complex internal investigations. She also has experience from developing internal audit, internal control and risk management processes as well as processes for assessing compliance risks as part of M&A transactions.

Qualifications

  • MSc in Business Administration (accounting & corporate law)
  • PhD student (corporate governance & compliance)
  • Accredited Anti-Bribery Specialist
  • Certified Internal Auditor
  • Certified in Controls Self-Assessment

Example services

  • hands on support based on extensive in-house experience from compliance, internal audit, internal control and risk management
  • ensuring adequate board/ management response to corporate conduct issues
  • providing well established assurance, compliance & anti-corruption expertise
  • building ethics & compliance programs that makes sense and meet regulatory requirements
  • Interim Chief Compliance Officer/ offloading the Chief Compliance Officer/ General Counsel
  • retainer based 'team member' supporting with e.g. project based work, investigations, remediation projects, training activities, design of improved/ updated policies, processes and controls,
  • preparation of compliance program plans, management and board presentations and reports
  • managing and coordinating complex internal investigations
  • corporate culture assessments
  • organizational ethics survey (Nordic survey benchmark)

PROFESSIONAL EXPERIENCE


prevent

  • With unique in-house experience from auditing, internal control, compliance and investigations I support companies with the design and deployment of an effective assurance framework.
  • How is the assurance work arranged for? Are the assurance, governance and control related functions working in silos? Do you make use of the scarce resources and existing information in a coordinated and structured way? More often than not we see that a compliance scandal could have been anticipated by the company and that indications of severe misconduct or weaknesses have been brought up in internal records and audit reports several years earlier.
  • I support companies with risk assessments, process and control development and training activities.
  • I will work together with the relevant internal functions to assess and develop an effective assurance framework and organisation. It can take the form as a 'combined assurance' activity, 'cultural risk assessment' , 'compliance monitoring' or developing a 'fraud prevention program and controls'.

DETECT

  • I have worked with designing and implementing an anti-bribery and corruption compliance program under the scrutiny of the US authorities and have first hand experience of what is deemed adequate and effective.
  • Fixing corporate conduct is always a change management effort creating frictions, struggles and contradictions which may be very exhaustive and time consuming for the internal team. As an interim expert I provide hands on support to the audit, compliance and other relevant teams throughout this period.
  • I am well placed to assist the Chief Compliance Officer and will work together with the organisation to ensure that the internal remediation efforts are adequately designed, implemented and followed-up.

RESPOND

  • During a process of detected corporate misconduct there is a lot ongoing in the organisation including e.g. law firms, forensic accountants, internal investigators and auditors. The Board and management must ensure that the reaction is adequate, timely and holistic. The remedial efforts must span across a variety of functions.
  • As a former Chief Ethics and Compliance (CECO) officer I will offload the CECO/ general counsel and take care of coordinating the investigation and remedial efforts, ensuring adequate documentation, execution and reporting to both internal and external stakeholders such as the board, and external stakeholders, such as regulators and investors.
  • I am very familiar with complex organisations and to work effectively and efficiently during a time of distress and urgency. I am used to navigate the political game within big corporations to get things done and to ensure Board and executive management buy in and commitment.