External Compliance Officer
Your external compliance officer, IT compliance included
A system that grows with you: from directors' liability and anti-corruption through money laundering and IT compliance to new legislation — with one fixed contact. Well suited to mid-sized companies.
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No obligation, no sales pressure
Compliance management system (CMS)
IDW PS 980§ 130 OWiG
The reality
Without a demonstrable compliance system, management is personally liable when something goes wrong. A documented CMS is what reduces exactly that risk.
The risk of waiting
Personal liability of the management for failures of supervision (§ 130 OWiG, German Act on Regulatory Offences), plus corporate fines of up to €10m.
The advantage of acting
A documented CMS signals trust to banks, investors and larger clients — and reduces the level of any fine should something go wrong.
Which companies need a compliance officer?
Mid-sized companies without a compliance department of their own
Management is liable for breaches of supervisory duties (§ 130 OWiG, the German Act on Regulatory Offences), even where nobody internally is explicitly responsible for compliance.
Suppliers to large corporations and public-sector clients
Customers and procurement offices increasingly ask for evidence, such as a code of conduct or a documented compliance management system.
What you get
A new law affects you? We check how it fits into the compliance management system you already have — no project from scratch.
- Risk inventoryAn overview of which compliance risks affect your company and how urgent each one is.
- Policy libraryWorkable policies — on anti-corruption or conflicts of interest, for example — written for your company.
- CMS to IDW PS 980A compliance management system built to the recognised audit standard, so that you can evidence it to third parties.
- IT complianceRequirements for IT, data and information security feed directly into your CMS.
- TrainingManagement and staff know their duties and know what to do when in doubt.
- A fixed contactOne person who knows your company and is reachable when new duties or official enquiries come up.
Most companies have more compliance than they think, but they cannot prove it. And proof is exactly what counts when a customer asks for evidence or management has to answer for a breach.
How we work together
Risk check
Where do you stand, which duties and risks are relevant?
Set up the CMS
Policies and processes to a recognised standard (IDW PS 980).
External officer on call
Ongoing support, training, and a contact for the authorities.
Several duties, one point of contact?
We will show you how a CMS cuts your workload.
- No obligation
- No sales pressure
Frequently asked questions
What exactly is a compliance management system (CMS)?
A compliance management system is the sum of the principles and measures with which a company ensures that rules are followed. IDW PS 980, the audit standard recognised in Germany, describes seven basic elements for it: compliance culture, objectives, risks, programme, organisation, communication and monitoring. A documented CMS is at the same time the strongest argument against personal liability of the management under § 130 OWiG, because it evidences the "due supervision" the law requires. In a court or regulatory review, a demonstrable CMS also reduces the level of any fine, even where it could not fully prevent an individual case. The CMS grows with your company and covers the compliance topics you need — directors' liability, anti-corruption, money laundering, sanctions and export control or ESG reporting duties, for example. Whether and to what extent a particular topic can be covered is something we clarify in the first conversation. When a new law arrives, we look together at whether and how it fits into the system you already have.
Is a CMS worth it for a small company too?
Yes. The liability rules do not distinguish by size, and a CMS is increasingly a prerequisite for public contracts.
Does this replace an internal compliance officer?
It replaces the need to hire one: you get the function without building a department. Your company still needs one fixed contact who coordinates internally.
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Daniel Tölgyesi
CEO
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