Case Study - Steele Compliance

Positive ESG impact of core business

Steele enables its clients to mitigate ESG risks, including bribery and money laundering through software, due diligence, monitoring and training. The company also provides other compliance services and solutions around business ethics and supply chain management, often through its subsidiaries (e.g. Compliance Wave) and partners (e.g. Whistleblower Security). 

The UN Sustainable Development Goals explicitly address bribery, corruption and money laundering in Goal 16 (Peace, Justice and Strong Institutions) and aim to “substantially reduce corruption and bribery in all their forms”. They estimate that corruption losses represent more than 5% of global GDP ($2.6 trillion) and bribes exceed $1 trillion, annually.

Moreover, beyond the obvious costs that bribery, corruption and money laundering impose on society, relevant regulations also impose significant monetary fines on corporate violators. Therefore, Steele’s services enable customers to mitigate ESG risk exposure and embrace compliance best practices, while also contributing to the pursuit of international sustainability goals and the overall betterment of society.

Good employment and diversity 

Steele has 162 employees, of which 78% are full-time workers. In addition, the company works with a globally distributed network of contractors to conduct the field portion of due diligence investigations. 

Given the knowledge-intensive, professional service and software development nature of the business, management’s main ESG priority continues to be managing its labour force as best as possible. As of September 2018, Steele has an annualised voluntary staff turnover rate of 8.7%, well below the industry average for professional services of 36.2% in the US.

To proactively track employee engagement and pre-empt potential issues, the company conducts exit interviews for all voluntary departures in addition to periodic engagement surveys. Subsequently, any feedback trends (positive or negative) that are identified are then incorporated into action plans.

Data privacy and security

Data privacy and security are relevant ESG themes for Steele, since the company collects substantial third-party personal, identifiable information. 

The company has assigned clear responsibilities for data privacy and security to its dedicated Data Protection Officer, IT Director and General Counsel. Bregal’s ESG review of the company confirmed that management exhibits a strong understanding of various privacy regulations. In 2019, management anticipates formalising further internal policies on data privacy and security training in order to maintain its strong ESG track record.