
Understanding risk and context
We help organizations identify where ethics and compliance risks truly arise before they escalate into incidents. Our ethics & compliance risk assessments, cultural and employee surveys, and research and benchmark analyses uncover the real-life situations, behavioural patterns, and pressure points organizations face.
Our risk assessments focus on how things actually work in your organization – not just how they are described on paper. We help you identify risks linked to human behaviour and compliance expectations, either across the full Code of Conduct or focus areas such as corruption, human rights, whistleblowing, DEIB, or ethical culture. Our risk assessment evaluates how well your written policies are put into practice and whether they address the risks most relevant to your organization.
Our cultural surveys give you an honest view into how ethical conduct and culture is experienced across roles, countries, and functions in your organization. They provide a safe way for employees to share what helps and what hinders ethical behavior.
Our research & benchmark analysis gives you a clear view of your current Code of Conduct or ethics and compliance policies, identifies gaps and improvement opportunities, and compares your Code against selected organisations. You gain practical recommendations for what to update, clarify or strengthen next.
Examples of our projects

Ethics survey for employees
In collaboration with Code of Conduct Company, Kommunalbanken (KBN) (external link) conducted an ethics survey among its employees to capture views and experiences from an ethical perspective. Code of Conduct Company supported the process by designing and tailoring the questions, managing the survey, and analyzing and reporting the findings.
The survey was targeted to all employees and included questions on how they perceive the organization’s ethical climate, the types of ethical concerns they had experienced, and how safe they felt speaking up about such concerns. The methodology was based on the Nordic Business Ethics Survey, which also provided a solid benchmark for comparison. KBN’s results were benchmarked against Norwegian results and Nordic financial sector results, enabling management to assess the organization’s ethical culture in a broader industry and regional context.
Good cooperation on a tested methodology, and with the necessary flexibility to meet the specificities of the company, but act with integrity. Ability to present the key findings at the top management level, balancing the key findings with depth, and providing insight to the results.”
Håvard Thorstad, Chief Compliance Officer, Kommunalbanken

Supporting Glaston in human rights due diligence
Code of Conduct Company acted as a partner to glass technology company Glaston (external link) in developing its human rights due diligence processes. The analysis based on key stakeholder interviews and a review of relevant documentation. We identified the most salient human rights–related risks and impacts on in Glaston’s operations and validated our findings in a workshop together. At the same time, we mapped existing risk management measures to mitigate negative human rights impacts and provided recommendations to ensure the implementation of human rights due diligence.
As an outcome of the collaboration, we produced a high-level human rights riskprofile, as well as the measures used to manage these risks and impacts. The analysis was conducted in accordance with the framework defined by the UN Guiding Principles on Business and Human Rights (UNGPs). The work also resulted in a public human rights commitment for Glaston.
We were very pleased with our cooperation with Code of Conduct Company in carrying out the human rights assessment and developing the related action plan. Niina and Kia took a highly practical approach and were able to tailor both the methodology and the scope to fit our operating environment.
The interviews were conducted professionally, and the project was delivered on time and within budget. The resulting roadmap provides a strong foundation for further developing our operations. I can confidently recommend Code of Conduct Company to other organizations undertaking similar projects!”
Kaisa Latva, Legal Counsel, Glaston Corporation

Ethics survey for city of Oulu employees
As part of developing the ethical culture at the city of Oulu (external link), the city conducted an ethical survey for its personnel in collaboration with Code of Conduct Company. The aim of the collaboration was to explore the views and experiences of Oulu city employees regarding the organization’s ethical practices.
Code of Conduct Company was responsible for implementing the ethics survey and analyzing the results. In the reporting phase, the results from Oulu were compared to reference data from Finland’s public sector, collected as part of the Nordic Business Ethics (NBE) Survey 2022. The survey was partially adapted from the original Nordic Business Ethics Survey, with additional themes specific to the public sector.
The survey focused on the realization of ethical conduct within the respondent’s work community in the following areas:
- Practices that support ethical conduct
- Addressing unethical behavior and consequences
- Ethical compromises
- Observations of unethical conduct
- Raising concerns
The collaboration was agile, and the survey was completed, analyzed and reported efficiently.”
Director of Internal Audit, City of Oulu
Q&A
Because you cannot build useful ethics and compliance practices in the abstract. Before updating a Code of Conduct, rewriting policies or launching training, it helps to gain deeper knowledge on what is actually happening and experienced in your organisation.
Understanding your context gives you a stronger starting point for developing your organization’s ethical climate. Instead of guessing what your organisation needs, you can focus on the situations that matter most.
A policy review tells you what is written down. We are interested how the policies and lived experience actually align in everyday work. For example, a policy may be clear on paper, but employees may still struggle to apply it. This work helps uncover those practical gaps and uncover your context and risks more thoroughly.
It is especially useful when you are about to renew your Code of Conduct, update compliance policies, build training or strengthen your ethics and compliance programme. It is also useful when there are suspicions that something is unclear, but you don’t yet have enough concrete information to know where to focus.
You gain a clearer picture on what needs attention and why. In practice, this can help you prioritize your next steps, direct resources more wisely, reduce exposure to legal consequences and make sure future work is based on your organization’s specific needs.
No. This work is just as valuable when things seem to be working well. It can help identify strengths, confirm priorities and prevent blind spots from growing into bigger issues. We believe that a healthy ethical culture is built by understanding the organization and its business environment before problems escalate.