Our team assists clients with designing, developing and implementing compliance policies and programs. We conduct regulatory risk assessments, and audits and investigations related to compliance practices. Our cross-practice team of compliance specialists can flexibly assist clients with preventing and handling of cases involving alleged or suspected financial misconduct, breaches of data protection and privacy, cybersecurity incidents, securities markets and financial services related non-compliance, antitrust infringements, as well as workplace-related non-compliance such as harassment and inappropriate behaviour. We also provide advice on governance-related matters and strategic advisory for managing conflict situations.
Our compliance team provides the first line of defence in various corporate crisis management situations as well as internal and external investigations, including related court proceedings. Our team members have broad experience in building effective strategic and procedural roadmaps to navigate such situations, devising internal and external communication strategies and managing interactions with the relevant authorities and enforcement agencies, such as pre-trial investigation authorities, the Finnish Financial Supervisory Authority, national and EU competition authorities, tax authorities, the occupational safety and health authority, the Data Protection Ombudsman’s Office and the National Cyber Security Centre.
Selected cases
Assisted several corporate clients in creating and updating compliance policies and procedures, including establishing whistleblowing channels, and in implementing group-level policies to the operations of target companies in connection with mergers and acquisitions. The policies have covered e.g. code of conducts and policies related to anti-bribery, anti-money laundering, anti-trust, competition, sanctions compliance, insider information, public disclosure obligations, privacy, data protection and workplace-related conduct, such as harassment and inappropriate behaviour. We have also provided clients with training on these matters.
Represented both global and Finnish corporate clients in multiple regulatory proceedings and investigations performed by administrative authorities, such as Finnish Financial Supervisory Authority (FFSA), Finnish Competition and Consumer Authority (FCCA), EU competition authorities, tax authorities, the occupational safety and health authority, the Data Protection Ombudsman’s Office, the National Cyber Security Centre and Energy Authority.
Advised leading service provider in Finland in an alleged cartel investigation by the FCCA, including assisting the client in a dawn raid conducted at clients’ premises by the FCCA.
Conducted “mock dawn raids” at clients’ premises and provided related on-site training on managing competition authorities’ dawn raids.
Advised a multinational listed company in and coordinated several cross-border internal investigations and related liability and disclosure matters regarding suspected breaches of code of conduct and other internal policies. The suspected misconducts concerned, inter alia, service payment arrangements with foreign agents facilitating sales and, bidding processes including significant payments to service providers. The investigations were performed with assistance of local law firms and forensics service providers.
Assisted a global listed company in cross-border internal investigation and related liability and disclosure matters regarding suspected breaches of internal policies and misconduct related to environmental health and safety matters in connection with a major construction project.
Advised several multinational listed companies in and coordinated multiple cross-border internal investigations and related liability and disclosure matters regarding suspected corruption and fraud-related misconduct, facilitation of significant payments to consultants, suspected kick-back payments in the operations of foreign subsidiaries of the companies, and suspected manipulation of internal financial reports. Most of these investigations were performed with assistance of local law firms and forensics service providers.
Assisted a Nordic group of companies in handling of a major cybersecurity incident involving a hostile outside actor targeting various sectors and materials, and in particular our client’s customers’ personal data processed in the group’s systems. The emerging questions and issues related to, among others, data privacy, contractual secrecy and other obligations, insurance aspects as well as communication with the authorities, police, current and former employees. We also advised the client in the mitigation of the incident’s effects including personal data subject communications and management of potential claims pertaining to the incident. The Data Protection Ombudsman’s Office decided not to impose further supervisory measures on our client.
Advised several listed and other companies in multiple internal investigations regarding suspected discrimination, bullying, harassment, and breaches of employment contract as well as breaches of the code of conduct and internal policies. Some of the cases have involved also suspected misuse of power and upper position in the top-management of the organization. Our advice has covered guidance in disciplinary measures and governance.
Represented a former board member of a multinational listed company in a police investigation regarding suspected breach of the disclosure duty of the company. The relevant issue in the case was whether a stock exchange release was delayed and whether the company had neglected to decide on delay of the disclosure of certain information to the market in a timely manner.
Represented an energy company in a police investigation related to suspected environmental crime related to a major oil leak at a site operated by the company. Our client was charged and convicted to corporate fine in the district court but in the appeal court all charges were dismissed.
Represented a global technology company as a plaintiff in multiple police investigations and related criminal court proceedings regarding violations of the company’s business secrets by employees and directors leaving the company after termination of their employment contract.
Represented a former employee of a Finnish listed company in a police investigation and related criminal court case related to trading of complex financial instruments. The case concerned a 34 MEUR claim for damages and charges of misuse of position of trust, and it resulted in dismissal of the case.
Represented a private investor to a start-up company against business secrets related criminal charges and damages claim amounting to over 12 MEUR. All charges and claims were dismissed.
Represented a Finnish company providing defense, security and aviation life-cycle support services and technology solutions in police investigations performed by the National Bureau of Investigation and related landmark court case with regard to corporate criminal liability. The case concerned an alleged aggravated bribery of foreign public officials in connection with supplying defense material to a foreign state. All charges and other claims were dismissed.
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