Compliance – policy


Corporate policies are frameworks that companies create to set guidelines for how the company and its employees are expected to act. These policies also add ethical guidelines to the legal frameworks provided in the countries in which they operate. To ensure that corporate policies act as successful drivers for compliance, companies must ensure that they adhere to and follow up on the policies which they have put in place.

All the interviewed companies have policies in place that in different ways state that criminal behaviour will not be accepted. The most commonly mentioned policies are IT policies, Codes of Conduct and Sustainability policies.

These are the policies that companies act on when someone has downloaded or viewed illegal material. However, the issue of child sexual abuse material (CSAM) is rarely clearly articulated in the policies. This is most often because companies believe that a general wording about illegal material gives them sufficient grounds to act.

“We don’t specifically mention what kind of material that is illegal. If we did, we would have to specify all other types of illegal material as well.”

IT policies

IT policies state that it is prohibited to use IT equipment to download or view illegal or inappropriate material. What is considered inappropriate material or websites, typically pornography, gambling, racist or otherwise offensive content, is specified. A description of illegal content is, as mentioned above and with a few exceptions, not articulated.

Code of Conduct

The Code of Conduct is another document that companies use as a framework for acting against CSAM in the business environment. Many Codes of Conduct include human rights, and working against child labour and different types of exploitation of children. Child sexual abuse (CSA) and CSAM are rarely articulated in these Codes of Conduct. However, as the Codes of Conduct are usually written in a way that includes a wider take on child protection, they often work as framework for the issue of CSAM as well.

Sustainability policies

Sustainability policies are often focused on environmental issues, but can also include human rights, such as acting against child labour and exploitation of children. Like the Codes of Conduct they don’t typically mention CSA, however the protection of children usually aligns with the policy.

Policy compliance

After putting ethical policies in place, it is important that companies evaluate their contribution and success. Hence, it is vital that businesses ensure that rules are followed and acted upon.

“There are not many ethical crimes which are followed up in this manner. But by preventing that company equipment is used for CSAM, companies can feel comfortable that their equipment is not misused in a way that can cause serious harm to children.”

“My role is to make sure that our employees use our equipment the way that it is meant to, and to act on all misconduct.”

Breach of company policy

A breach of company policy will lead to disciplinary action. When someone is found to have used their work computer to handle CSAM, dismissal is very likely. The companies all state that if they find evidence of someone handling CSAM on the work computer they will report it to the police. However, in some countries the police do not investigate possession of CSAM. In these cases the company will instead take disciplinary action based upon breach of company policy.

Comment to insight 7, 8 & 9

More results from the NetClean Report 2020