Dan Ostergaard · Co-founder, Trusty · Former Novartis Global Head of Compliance · Founder of PolicyStore
At Trusty AG, our headquarters are nestled in Zug, Switzerland, a picturesque lakeside town ringed by mountains. Tourists flock here for boat tours on the serene lake, and while operators are happy to provide the experience, they also know the risks. Accidents have happened, and liability is real. So today, they act with caution, or at least appear to.
One precaution some tour operators now take: requiring every single passenger to wear a life vest. No exceptions. Everyone gets one, and the crew ensures it’s worn properly before the boat leaves the dock.
Some people appreciate this. Others roll their eyes. “I just won the Ironman on this very lake,” one might say. “I could probably tow this boat to shore myself.”
To avoid bad reviews from such elite swimmers, imagine if the boat crew took a more “corporate” approach:
- Passengers under a certain age, or over a certain age, must wear life vests.
- Others are asked a few screening questions: Can you swim? How often do you exercise?
- And a few are invited to prove their skills in a five-minute swim test.
This way, our Ironman hero could cruise in his T-shirt, admired by the rest sweating in neon vests.
It might earn a few more stars on TripAdvisor. But is it worth it?
The corporate compliance life vest parallel
This story reflects how many companies approach compliance, and why we call our answer the compliance life vest: with customized, complicated processes that look risk-based on paper but leave huge gaps in practice.
Why don’t companies just “hand out life vests” to all their suppliers and business partners?
Because proper risk assessments are hard.
They require coordination between departments, accurate contact lists, timely responses, and actual engagement from business partners. Even when companies manage to send out due diligence questionnaires, most of their suppliers still show some elevated risk. That forces prioritization, which usually benefits the handful of partners already under close supervision.
The rest get filtered out under the “proportionality principle.” And yet, every seasoned compliance officer knows: the real risks hide in the long tail of unmanaged partners.
That’s where scandals begin, not with the polished few already under the spotlight.
Why not just distribute life vests?
Some companies try, but in symbolic ways. They send out Supplier Codes of Conduct and ask partners to sign and return them. It’s compliance theater, the opposite of a compliance life vest.
It’s like asking every boat passenger to sign a form saying they swim better than Michael Phelps, while reassuring them it’s “just a formality.”
But when things go wrong, regulators don’t care about fine print. They care about action.
A real compliance “life vest” isn’t a signature on a code of conduct. It’s a system.
Regulators (and prosecutors) expect:
- Clear, enforced compliance policies
- Regular, risk-based training
- A secure, anonymous whistleblower channel
- Ongoing third-party monitoring
These aren’t optional. They’re the foundation of an “adequate procedure” under laws like the UK Bribery Act, FCPA, and OECD Guidelines. They often determine whether a company faces liability, or proves it took meaningful steps to prevent misconduct.
Why smaller companies struggle, and how a compliance life vest helps
Despite their importance, these systems have historically been too expensive, too complex, or too slow for most small and mid-sized companies.
Even modern compliance tools tend to stop at risk identification. They flag problems, send a report, and leave the rest up to you.
Trusty was built to go further.
We don’t just identify risk in your supply chain, we help reduce it. Our platform equips your partners with real tools, so they meet your standards, improve their practices, and reduce your exposure.
The Trusty Compliance platform includes:
1. Supply Chain Monitor
Go beyond screenings. Identify ESG, sanctions, corruption, human rights, and deforestation risks, then invite partners to close their own gaps with built-in tools.
2. Compliance App
Access a full library of core compliance policies: anti-corruption, labor rights, non-discrimination, environmental protection, whistleblower protection, health and safety, and more. Share and track them instantly.
3. AI Learning
Policy training made simple. Lightweight, effective, and certification-ready, no LMS required.
4. Whistleblowing Solution
Provide a secure, anonymous reporting channel fully aligned with the EU Whistleblower Directive. Available to third parties too.
When you onboard partners with Trusty, they don’t just get checked, they get better.
Compliance that grows with your partners
Suppliers who engage with the Trusty platform receive First Level certification, proving a foundation of compliance is in place. Once they activate and use the full suite of tools, they’re eligible for Advanced certification, making them lower-risk and higher-trust partners.
As a client, you can track all of this transparently.
And for suppliers? Everything is available for €490 per year. No installations. No IT integration. Just plug, play, and comply.
Life vests for EUDR compliance
Trusty goes even further for companies navigating the EU Deforestation Regulation (EUDR). Our platform includes dedicated due diligence tools:
- Request geolocation and legality information from suppliers
- Conduct legality and deforestation risk assessments
- Generate and submit DDS via TRACES
- Track and store EU reference numbers
But we don’t just support buyers. We help suppliers understand what’s required, collect documents, prove legality, and build credibility. With our help, suppliers can:
- Meet complex due diligence requirements
- Reduce buyer-side risk
- Make it easier for clients to submit valid DDS (which requires zero or negligible risk)
And with our optional “EUDR Passport,” suppliers can:
- Store legality documents securely
- Reuse compliance evidence for future requests
- Avoid duplicate submissions and endless email chains
Looking for EUDR software? EUDR Passport collects your supplier data, runs the risk assessment and files unlimited due diligence statements, from €90 per product profile per year.
Real compliance. Not just declarations.
Giving your partners real tools, not just paper promises, isn’t just smarter. It’s safer. It reduces liability, builds trust, and proves due diligence when it matters most.
So maybe compliance is about life vests after all. Not about who can swim, but about who’s protected when the storm hits.
With Trusty, your partners don’t just stay afloat. They thrive.
Frequently asked questions
Giving every employee, partner and supplier the same basic protection, clear policies, short training and a way to report, instead of a tailored, risk-based programme that only covers those judged most exposed and leaves gaps.
Proper risk assessments need coordination between departments, accurate contact lists and engagement from partners. Most suppliers show some elevated risk, so prioritisation favours the few already under supervision while the long tail stays unmanaged, and that is where scandals begin.
Clear, enforced compliance policies, regular risk-based training, a secure anonymous whistleblower channel and ongoing third-party monitoring, the foundation of an adequate procedure under laws such as the UK Bribery Act and the FCPA.
No. A signature on a code of conduct is compliance theatre. Regulators care about action, and a real compliance life vest is a system of policies, training, reporting and monitoring.
POLICIES, TRAININGS AND HOTLINE
Trusty Compliance App: company policies, compliance training and a whistleblowing channel in one app for your employees. 10 ready-made policies, 6 trainings, free trial, no IT setup.