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AmCham Sweden is the voice of American business in Sweden. We are champions of US - Swedish trade and investment and US commercial interests in Sweden and give members a networking platform, critical business information, and an amplified voice.


Importance of Codes of Conduct Increases for Swedish Businesses

Jacob Dornbos

On February, 4, 2014, AmCham Sweden members gathered at the offices of KPMG in Stockholm as Johan Kahn, Partner & Advokat at Delphi and Martin Krüger, Partner & Head of Forensic at KPMG presented findings from the third study their two firms have jointly conducted on Codes of Conduct for the 50 largest publicly listed companies on NASDAQ OMX Stockholm.

“I first became interested in Codes of Conduct after serving as a legal advisor in outsourcing deals,” Johan Kahn said. “The issue became more apparent for me when I began working with off-shore deals in India. Then, last spring, Martin Krüger and I made this the main topic of the third study we have conducted together since 2009.”

Some of the findings of the study reveal that 84% of the 50 companies Kahn and Krüger have followed over the past five years have a Code of Conduct in place. Of these companies, 67% have had some sort of violations of the code they have implemented, and according to Krüger, probably more. In addition, 92% of the companies stated that their code is relevant to their suppliers as well. However, Krüger noted, because a Code of Conduct is not a contract, it can be difficult to enforce.

Both Krüger and Kahn stressed the importance of due diligence as part of any sourcing process that companies conduct, whether they are purchasers of goods or services, or vendors that may be included in a company’s supply chain. “There needs to be some time spent on an audit of your suppliers before agreeing to terms of a contact that is signed between parties in any business deal,” Kahn stated.

The subject of how “whistle-blower” policies are enacted by different companies was also addressed, and how cultural differences between Swedish companies and those from the US, for example, help or hinder efforts to bring attention to fraudulent behaviour that company employees may be engaged in. “Who are the typical fraudsters?” Krüger asked. He then answered with figures gathered from the Codes of Conduct study. “90% of fraudsters are men, and 70% of them are between the ages of 36 and 55 years old.”

Citing the growing trend in cyber crime and results of other recent studies on the subject of ethical behaviour, Kahn and Krüger offered insights on how applying Codes of Conduct to external business partners and suppliers can be implemented in standard practices by Swedish businesses.

The complete report complied by KPMG and Delphi: Codes of Conduct in the Swedish Business Sector is available to AmCham Sweden member companies and may be downloaded here: For more information, please feel free to contact either Johan Kahn, Partner & Advokat at Delphi or Martin Krüger, Partner & Head of Forensic at KPMG.

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