CASE STUDY
Increasing compliance with a sovereign wealth fund’s Code of Conduct
Challenge
Sovereign Wealth Funds (SWFs) must comply with regulation across multiple jurisdictions. At the same time, they are constantly engaging with organisations and partners worldwide, who speak different languages and operate within different regulatory systems.
Senior risk managers at this particular SWF wanted to embed a culture of compliance throughout its own and its partners’ organisations.
The challenge, however, was that their Code of Conduct (CoC) had been compiled by multiple lawyers and risk professionals, across a number of countries. As a result, the document – which used English as a common language – was complex and extremely difficult to engage with and understand.
SWF’s head of risk knew that Wordtree understood the regulatory environment – and that we had long experienced of partnering with reg risk and legal colleagues. So he asked us to re-create the CoC. The vision was for it to become so easy to use that it would become a daily resource for all stakeholders – even if English was not their first (or sometimes second or third) language.
Solution
CoCs are extremely important – and in rewriting them, you have to make sure they remain legally robust. The consequences for not doing so can mean that an organisation like an SWF can fall foul of international law and incur sanctions.
This meant that we needed to foster very high levels of trust from the outset. Once we’d reviewed the document thoroughly, we talked to senior legal counsel to get their buy-in and support.
We then set up a meticulous tracking system to log where information had been captured – and where it had been redeployed to in the new document.
With this in place, we started the process of parsing out all of the information in the 100,000+ word document – and reformatting it into a quick-reference resource.
Key to this process was simplifying the language to make it immediately understandable – and structuring the document to make it easy to skip to relevant sections. We also introduced diagrams, flow charts and decision trees to make processes super-easy to follow.
At all stages, we worked with our clients’ legal teams to ensure complete accuracy.
Results
The resulting document was circulated throughout the organisation and introduced into onboarding of all new colleagues and partners.
The number of compliance-related issues fell. And legal counsel reported that after the relaunch of the CoC, colleagues were more likely to reach out to them for clarification around complex situations. They welcomed this development and said the CoC had made them feel more approachable.
Legal colleagues have now also incorporated our content tracking system into their own work.
Discover other examples of our work
Repositioning a professional services organisation to allow it to communicate a differentiated advisory offer
“The new Code of Conduct has been distributed to all colleagues across the world and has gone down very well indeed. It has been of real practical help. So again, your work has been much appreciated, and we are most grateful.”
Head of Regulatory Risk
Global data and analytics company