For much of the past decades, companies could build integrity programs around a set of broadly converging international rules. That shared direction is now shifting.
In a new white paper, Coherence by Design, the Coalition for Integrity, with Yousuf Aftab and Jonathan Drimmer of Steptoe LLP, examines how expectations on corruption and human rights are moving apart across jurisdictions. US and European enforcement increasingly reflect different priorities, and a single supply chain can face different obligations on either side of the Atlantic. A program calibrated to any one regulator fits the others less well than it used to.
The paper argues that this divergence makes integrity a governance question, not just a compliance one. Because anti-corruption and human rights risks share common drivers, and the most material harms are themselves integrity crimes, companies may be better served by a single, integrated due diligence architecture than by parallel, single-issue programs. A case study of Airbus illustrates what that can look like in practice.