Sweden: Revised Ownership Policy for State-Owned Enterprises

Sweden: Revised Ownership Policy for State-Owned Enterprises

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November 25, 2015

spotlight Compliance Champion Spotlight

What is a Compliance Champion? A Compliance Champion is an individual or organization committed to fostering and raising the standards of anti-bribery compliance. TRACE Trends will include posts featuring Compliance Champions from time to time.

We hope you enjoy the following entry from this week’s Compliance Champion, and TRACE Partner Law Firm!

Today’s guest blog post is written by Natali Phalén and Mikael Rydkvist of Setterwalls law firm in Stockholm, TRACE’s Partner Law Firm in Sweden. Setterwalls is one of Sweden’s leading full-service law firms with a well-established international network. Both Natali and Mikael are members of Setterwalls anti-corruption team and regularly assist clients with policies and procedures and advice on risk management as well as conduct investigations.


This summer, the Government Offices of Sweden revised its ownership policy for state-owned enterprises (SOEs) to include a reference to the Code of Business Conduct of the Swedish Anti-Corruption Institute. The revision means that all Swedish SOEs are now expected to follow the Code.

The policy change affects all of the approximately fifty fully or majority state-owned companies in Sweden, as well as privately-owned companies conducting business with these SOEs. The Code clarifies and complements the Swedish criminal provisions on anti-bribery, but also contains provisions that are stricter than the criminal law. Accordingly, a company in compliance with the relevant criminal provisions may nevertheless be in breach of the Code.

The addition of the reference to the Code in the ownership policy for SOEs is a mark of the increasing focus and attention in Sweden on the issue of anti-corruption. Sweden has long been considered a country free of corruption, and although Sweden is still one of the most transparent countries with a low degree of corruption, misconduct still occurs. Further, following several recent public scandals regarding corruption in Sweden and abroad, some involving SOEs, the image of Sweden as a country free of corruption may have slightly shifted. The increased focus on these issues is, therefore, at least from our perspective, important and highly welcome.

As a consequence of the change in the policy, some – or perhaps several – SOEs will now need to review and possibly amend their internal policies and procedures on conducting business. Companies dealing with Swedish SOEs should be aware of the content of the Code, and exercise caution to ensure that business is being conducted in adherence to its standards. 

For more on this topic, please see the following resources:

The Code of Business Conduct of the Swedish Anti-Corruption Institute
The Swedish Anti-Corruption Institute
How State Owned Companies Are Managed

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