It takes two seconds to say ‘zero tolerance against corruption’ and there are plenty of statements about being an ethical company and about 'doing the right thing. Corporate scandals however, reveal a gap between what is said and what is actually done. There is a will but the way seem to be lost.

Responsible corporate conduct is not about CEO statements and words fine-tuned by communications departments. Responsible corporate conduct is about how the words are put into action and whether the action lead to real and lasting change.

In their book, The Grey Zone, authors Michaela Ahlberg and Anna Romberg describe what it takes to put the policies, processes and framework of compliance in place and present a framework for moving “from Words to Action and From Action to Change”.

The authors share practical considerations and thoughts on effective compliance work. The work is based on five fundamental Cs: Context, Content, Compliance, Conduct, and Culture.

Context and Content are words.

Compliance relates to activities that translate words into action.

Conduct and Culture facilitate lasting change.

All of the elements, Context, Content, Compliance, Conduct and Culture, are required to truly address and manage corporate conduct.

Compliance brings transparency, makes difficult dilemmas visible and generates friction.

The friction and dilemmas require decisions and actions, a conduct. Conduct demonstrated in the daily decisions and actions will inevitably generate a culture. Words do not create culture, action does.

In a perfect world, a company would be able to start from understanding its context and then work onwards with content and compliance, conduct and culture. We realise that hardly any company starts with this work from a blank paper, and one has to adapt to what already exists. This framework provides a methodology of elements, which should ultimately all be in place for managing corporate conduct and our view on what to expect during the implementation and continued work. It will help you plan the work, ensure effectiveness, identify where there is room for improvement and perhaps to understand why the work may feel overwhelming at times. Struggles and frictions are natural part of change, and we encourage embracing these and using them as fuel for change. Based on our experience, the struggles and frictions are actually evidence of the programme having an impact and that the journey towards change has started. All the hard work will pay off in a more responsible corporate conduct and stronger culture of business ethics.