2024 Ethics and Compliance Recap: Insights and Key Trends Shaping 2025
This has been an extremely eventful year for the Ethics and Compliance community. Major regulatory enforcement actions, a big Evaluation of Corporate Compliance Programs guidance update from the Department of Justice, the operationalization of artificial intelligence, evolving supply chain risk, and many more issues have made the best practices of the business integrity space more valuable than ever before.
As we look back at some of the most important issues that shaped the past year, Ethisphere thought leaders will also look ahead at what challenges and opportunities are worth considering for 2025.
On Leadership
Tom Bubeck Chief
Journeys and missions are not linear. They have ups and downs that must not derail the mission. As we head into 2025, we need to reflect on what has worked and what hasn’t and learn, grow, and adapt. To move ahead mindfully, reflectively, and bravely.
On Governance
Erica Salmon Byrne
2024 gave us fresh examples of what a lack of effective board oversight can mean, most notably in the TD Bank settlement. The explicit adoption of ‘zero expense growth’ without any apparent discussion of what risks that entailed should be a table top exercise for every smart board in 2025. I’ll also be keeping an eye on how boards are evaluating the ‘de-siloing’ expectations laid out in recent DOJ guidance; they should be seeing more explicit coordination between control functions going into next year, and if they’re not seeing that, they should be asking why.
On AI and the E&C Tech Stack
Nausheen Moulana
In 2024, Ethics & Compliance teams effectively leveraged Gen AI for automating processes like training, policy management, and speak-up culture, while continuing to employ traditional AI and data analytics for areas such as AML, tax compliance, trade surveillance, and supply chain risk management. This progress was marked by a careful balance between utilizing technological innovation and addressing critical risks, including data privacy, security, intellectual property, and reliability/accuracy of AI-based outcomes.
In 2025, focus on integrating data and enhancing observability in the E&C technology stack and systems will be key. Breaking down silos to create a 360° view of data required for E&C use will empower teams to further leverage AI and data analytics to obtain insights and actionable intelligence across E&C ownership areas, predict and address risks, prioritize actions, and monitor program progress effectively.
On the E&C Community
Kevin McCormack
Diversity is a hallmark of the BELA community. Diversity of issues that E&C leaders are facing; diversity of roles and risk owners; diversity of industry; and diversity of markets. It’s on full display during our Global Ethics Summit, but throughout the year it is captured in the 50+ BELA roundtables hosted both in-person and virtually. The voice of BELA is a powerful one and the knowledge exchanged at these roundtables is even more powerful. Whether the focus has been on peer example of leveraging Artificial Intelligence tools to increase compliance capabilities or inviting dialogue with Chief Compliance Officers, and our SMEs from Ethisphere, on the impact of new DOJ guidance, the community has played full out in 2024. Candid in conversation and supported by both data and tested practices, there is arguably no better platform to surface new ideas, ask the tough questions, and do so together.
2025 will require Ethisphere, in partnership with the BELA community, to build on that momentum. We will continue to seek a better balance between breadth and depth. Industry-specific depth is one roundtable attribute that we will see in 2025 as we are experience a groundswell of interest in sectors that have unique challenges, inclusive of software & tech, healthcare, insurance, retail, and manufacturing. Depth of external authorities that can offer even more guidance to the BELA community as we continue to assess the road ahead with ongoing A.I./tech disruption, supply chain challenges, regulatory shifts, ethical culture risks, and more. We often talk about the need to have best practices in place for ongoing monitoring of risks. We will need to apply a similar approach so that our BELA roundtables can pivot as we assess where our community needs the support the most. What gives us confidence is that BELA continues to demonstrate, year after year, that it is a rising tide that lifts all boats and among the most trusted sources for everyone who participates as they did in record numbers this year.
On Culture
Doug Allen
The big, macro piece on Culture this year is the reference to it in the latest Department of Justice update to the Evaluation of Corporate Compliance Programs guidance. That really brought culture front and center in a way we have not seen before. The case for why culture is so important has never been made more clear. And complimenting that is the research we have provided that determines that organizations that perform well on our culture assessment also perform well overall as businesses. Combined, those highlights made a clear case for why we measure culture.
For 2025, what’s at top of mind for us is how well folks integrate a smaller suite of questions from their engagement surveys or, how they implement speak-up culture. We’re looking at how organizations don’t want to over-survey, so how can they get visibility on data that is timely, accurate, reliable, and most of all, good? As all that comes to bear, we’re increasing looking through a lens of going outside of full-blown surveys and drilling down more on how folks are integrating smaller, more regular interactions like pulse surveys that provide just-in-time data around specific topics.
On Supply Chain
Craig Moss
The past year was dominated by a renewed focus by companies on supply chain resiliency. This was driven by the lingering effects of several major, unexpected disruptions–the COVID pandemic, the Suez Canal blockage, the war in Ukraine, etc. The evolving geopolitical landscape signaled an end to the drive to having a single highly efficient, low-cost global supply chain. It forced companies to start to think about creating constellations of suppliers to serve specific market segments due to local regulations or customer demands. The 2024 approval of the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) highlighted a growing trend toward sustainability regulations that will accelerate the need for companies to embed managing sustainability performance and risks into how they manage their supply chain. The CSDDD goes far beyond requiring a company to know the environmental and social risks of their suppliers. It requires remediation, monitoring, and reporting. One of the major challenges that emerged in 2024, was getting reliable data. Adding environmental and social requirements to the list of other compliance requirements, including anti-corruption, data privacy and trade sanctions, made resiliency a bigger challenge than ever.
Looking to 2025, there are two major themes companies should focus on. First, how will you implement a supply chain risk management program that sufficiently covers the breadth of your supply chain and delivers a scalable way to go in-depth with your key suppliers? For the key suppliers, a combination of technology and human expertise will provide visibility beyond a supplier’s inherent risk and into how mature their systems are that manage those risks. With key suppliers, it is important to take a “measure and improve” approach. Part of making this practical is to think holistically about the spectrum of compliance and ESG risks and prioritize what needs to be addressed based on what is more relevant and material to the business. This will increasingly drive the need for cross-functional collaboration about what is critical to address and how to do it a practical way.
Second, how can you start to explore the use of AI (Generative AI, specifically) to improve supply chain resiliency and risk management? This is an area that will see a lot of attention. The key for companies will be to start with the specific problem they are trying to solve with Gen AI and to determine if they have the reliable data that is needed.
To stay abreast of the latest trends and issues in the field of business integrity, be sure to visit the Ethisphere Events page to register for upcoming webinars, roundtables, and the Global Ethics Summit.
And to draw on the best thought leadership in the ethics and compliance space, check out the Ethisphere Resource Center, for a wealth of free reports, white papers, interviews, and the latest issue of Ethisphere Magazine.