Ethics & Compliance

Building capabilities for effective, value-driven compliance and ethics programs.

An increase in the scope and geographical reach of ethical and compliance risk in recent years means organizations must now be better prepared than ever before to not only understand their exposure to compliance risk but take forthright action to mediate its effects. Ethics and compliance are about more than prevention, it is also about navigating opportunities.  Opportunities which can strengthen your organization through strategic, proactive measures—such as best practices, internal controls, and appropriate reviews and assessments for your industry and size.

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PwC Turkey Digital Compliance Platform

We moved Ethics and compliance management to a digital platform! Thanks to our technology consisting of integrated modules, you can manage your ethics and compliance risks effectively and easily through a single platform.

Bribery and corruption are business world’s one of the most challenging issues. Yet despite efforts of national and international levels to tackle bribery and corruption, it remains a significant issue. Recognizing this, we help you to respond Anti-Bribery and Corruption (ABC) risks and concerns. We support our clients managing their obligations under the UK Bribery Act 2010 and the Foreign Corrupt Practices Act (FCPA) and the increasingly complex global bribery regulations and country laws. With increased enforcement in both the financial and non-financial sectors, it is important that companies have a robust ABC compliance framework to mitigate the risk of non-compliance and potential enforcement action.

Foreign Corrupt Practices Act (FCPA) Compliance Review

  • Review of Compliance Environment
  • Review of Organizational Documents and Other Corporate Records
  • Review of Certification and Licenses
  • Integrity Due Diligence
  • Review of Chart of Accounts and Transaction Testing

Daha fazlası

UK Bribery Act (UKBA) Compliance Review

  • Review of Compliance Environment
  • Review of Organizational Documents and Other Corporate Records
  • Review of Certification and Licenses
  • Integrity Due Diligence
  • Review of Chart of Accounts and Transaction Testing

Third Party Review for Anti-Bribery & Anti-Corruption Compliance

Our anti-corruption professionals have relevant experience, knowledge and global reach. They help our clients understand and respond to anti-corruption compliance in all its phases, even when their businesses span many jurisdictions and are governed by different regulators.

Our services, which meet domestic and international standards, include:

  • risk analysis and gap assessments
  • evaluating, designing and implementing programmes
  • designing and running training programmes
  • performing bribery and corruption investigations as well as asset tracing and relationship identification across jurisdictions
  • anti-corruption due diligences, as part of an acquisition or a sale of the target company or in other relevant circumstances.

As a result, we help organizations to:

  • protect their reputation at home and abroad
  • update, refine and streamline their compliance measures
  • minimize losses – both direct and indirect – related to corrupt acts
  • build productive working relationships with regulatory bodies
  • promote themselves as thought leaders in business ethics.

Pre/Post Deal Compliance Assessment

We help you build competitive advantage by enabling your ability to assess potential risks of a target, including regulatory risks, bribery and corruption matters, financial crimes and other threats. The result? You can protect your deal value and accelerate your business strategy. 

During Pre-Deal Anti-Bribery and Corruption reviews, we assess the transaction in terms of anti-bribery and anti-corruption compliance by:

  • Review of compliance environment
  • Review of organisational documents and corporate records
  • Review of certification and licenses
  • Integrity Due Diligence research on the target company and related parties
  • Review of chart of accounts and sample financial data

Post-Deal Anti-Bribery and Corruption reviews involve review the financial statements to identify any red flag indicators of potential leakage payments associated with the counterparty and its related parties/persons whether they have received or benefited from any amount of leakage. The assessment includes the following:

  • Trend analyses on leakage related accounts
  • Targeted payment review associated with the counterparty or related party/persons
Click on details for Anti-Corruption & Bribery Reviews service

Anti-Money Laundering refers to a set of laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.

AML Risk Assessment

Key control areas for AML Assessment

  • Governance
  • Customer Due Diligence
  • Monitoring Customer Activity
  • Suspicious Activity Investigation and Escalation
  • Management Information
  • People Management and Training
  • Monitor and Improve Effectiveness of Controls

AML Program Design, Implementation & Monitoring

Where do you stand on compliance with AML regulations?

Do you understand the consequences of the crime of money laundering?

We provide the following services within this context:

  • Preparation of corporate policies and procedures for Anti-Money Laundering and financing of terrorism; coordination of related oversight, detection, training and internal audit activities
  • Assessment on regulatory compliance of current corporate procedures and implementation of necessary remedial measures
  • Assessment of compliance with foreign legislation for obliged parties with partners resident outside Turkey and implementation of necessary remedial measures
  • Advisory services for establishment and implementation of the required IT infrastructure and assessment of the effectiveness of systems already in place
  • Identification of high-risk operations and assessment of necessary remedial measures during mergers and acquisitions via review of procedures and past transactions of target companies

AML Data Analytics

Through data analytics, we can help your organization meet the challenges of AML and KYC:

  • Creating AML incident scenarios
  • Using analytical tools to test AML scenarios
  • Identifying potential risks associated with AML compliance

Know your Customer (KYC) / Client Due Diligence

Various Anti Money Laundering (AML) regulations require financial institutions to undertake customer due diligence measures, including identifying and verifying the identity of their customers.

The range of measures depends on the clients’ risk assessment in regard to the likelihood of money laundering and terrorist financing.

  • We offer support in design and implementation of suitable end-to-end KYC operating models, development and optimization of KYC processes and procedures, as well as review, support in selection and implementation of IT solutions dedicated to KYC processes.
  • We can also provide operational support for your KYC Business as Usual processes or design and deliver remediation of deficient KYC files through our Centre of Excellence.  
  • We are also supporting financial institutions in the review of KYC functions from the compliance perspective. This includes independent review of group and local policies and procedures against regulatory requirements.
Click on details for Anti-Money Laundering (AML) Reviews service

Ethics and compliance management is essential for prevention and detection of misconduct and compliance breaches. We help you mitigate your ethics and compliance related risks with implementing effective ethics and compliance programs.

Ethics Hotline Implementation

Ethics hotline and reporting mechanism play a crucial role in detection of fraudulent or unethical incidents in organizations. We can help you establish an end-to-end ethical case management system and process within the scope listed below.

  • Implementing end-to end ethics reporting and case management system, Ethics Help Center
  • Designing ethical reporting and assessment process
  • Composing whistleblowing and ethics case management procedures
  • Assuring the support and commitment of top management / executives
  • Helping communicate ethics and whistleblowing program throughout the organization
  • Harmonizing ethics case management with your compliance program

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Ethics Hotline Management

Today, the priorities of the companies are to create a common corporate culture, to protect the reputation of the Corporation, to improve the behavior of employees, to comply with legal requirements including EU Whistleblowing Directive and ISO 37301, to meet the expectations of stakeholders, to be a responsible company to society, to strengthen the position of the company against competitors, to reduce the effects of misconduct by creating an Ethics Code / Regulation and manage the ethical reports. In this context, we will provide you with the following support for the development of the ethical culture:

  • Assisting you in assessing and improving ethics case management process
  • Meeting with Senior Management regarding the tone at the top impact on ethics culture
  • Providing Ethics Trainings to management and employees
  • Evaluation and improvement of the Code of Ethics
  • Assessing employee’s perception on whistleblowing mechanism and recommending actions to improve ethics culture

Code of Ethics Policy & Procedure Design

Code of Ethics & Conduct helps to demonstrate Organisation’s awareness and shape its responsibility in front of employers, customers, business partners, communities and competitors. It facilitates the Organisation’s ability to make a difference on a market. Moreover, it helps to articulate the Organisation’s expectations to its employees much clearer and positively influences their behaviours. Code of Ethics & Conduct is an essential attribute of any Organisation that aims to secure its profitability, brands and reputation on the market.

We help to enhance corporate culture in Organisations through support with design and implementation of strong and effective ethics and compliance practices.

Compliance Program Assessment

  • Reviewing the Company’s current operations from a compliance aspect such as an ABAC and trade control & sanctions perspective
  • Review of the Company’s key documents including current policies and procedures;
  • Assess the Company’s current stance with respect to compliance and trade controls;
  • Site visits to the Company’s offices to hold workshops with Company management (including: key executives, business unit leaders and relevant people from legal, finance, internal audit and compliance teams) to understand Company controls with respect to bribery, corruption and trade controls / sanctions;
  • Identify Company’s compliance related risks and improvement areas with respect to the current regulations including: Foreign Corrupt Practices Act of US, UK Bribery Act, OECD Convention, and US Trade Controls and Sanctions.
  • Provide you with a legal memorandum (in conjunction with legal counsel) identifying risk and improvement areas and our recommendations to mitigate those risks and enhance the current compliance program.

Compliance Program Design & Implementation

Phase 1 - Assessment

  • Assessing the current control environment and identifying the gaps/risks with regards to ABAC, AML & Sanctions and Ethics compliance design via interviews with process owners

Phase 2 – Road Map to Compliance Program

  • Determination of compliance risks and drafting enhanced policies and procedures for the Company.
    • Anti-Bribery Anti-Corruption
    • Anti-Money Laundering & Trade Sanctions
    • Ethics

Phase 3 - Implementation of Compliance Program

  • Providing full day training sessions for the Company’s management and selected group of managers.
  • Provide ad-hoc assistance and guidance to the Company during the implementation of the compliance program. 

Contract Compliance Reviews

Entitlement assessment and contract compliance

Make sure you’re paid or paying the appropriate fees under the licensing agreements and supplier or vendor contracts.

Different accounting policies and practices, as well as changes in accounting guidance, can impact key calculations under these agreements, affecting terms such as sales returns, damaged goods and consignment sales. Understand your agreement to make sure you’re getting what you’re entitled to.

In the event of a dispute, our experienced professionals can support your claim with legal and alternative dispute resolution methods.

Contract Optimization

  • Data Analytics and Customer Contract Tool
  • Decision Making and Negotiation Strategy
  • Pilot Negotiations and Settlements


Distributor/Agent Reviews

On-site review of selected distributor and agents to identify potential irregularities by understanding general business practices, corporate relations, compliance environment, potential conflict of interest and suspicious transactions to assist your organization in mitigating third party risks.

Competition Investigation Support

Our forensic experts help you with Competition Investigation Support which includes the following compliance procedures:

  • Review of compliance with regulatory framework related to competition
  • Developing strategies for mitigating the risks of possible competition law violations and establishing corporate policies for managing key risks
Click on details for PwC Turkey Digital Compliance Platform

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Gökhan Yılmaz

Gökhan Yılmaz

Forensic Services Leader, PwC Türkiye

Tel: +90 212 376 5302

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