People, Risk & Compliance – From Culture to Control

Much has been written about the complexities of managing people in a global workplace, but the challenge for employers is no longer confined to setting cultural baselines. Increasingly, the focus has shifted to how organisations design and operate effective governance and internal frameworks, from whistleblowing and investigations to anti-bribery and compliance controls, that support consistent, transparent and defensible decision-making.

As regulatory expectations continue to evolve, employers are expected not only to establish appropriate policies, but also to demonstrate that those policies operate effectively in practice. This includes responding to complaints, conducting investigations, documenting decision-making and managing sensitive workplace issues in a way that is fair, proportionate and compliant with local legal requirements. Increasingly, regulators are scrutinising not only the outcome reached, but also the process followed to reach it.

Across many jurisdictions, employment law reforms are reinforcing this trend. Recent legislative developments place greater emphasis on internal governance, documented procedures, regulatory oversight and employer accountability. Whether through enhanced whistleblowing protections, structured dispute resolution mechanisms, increased record-keeping obligations or expanded enforcement powers, employers are expected to demonstrate that workplace decisions are supported by robust governance and effective compliance frameworks.

In this issue, we explore how these themes are developing across key jurisdictions and highlight the practical steps employers should consider to strengthen governance, reduce risk and respond confidently when workplace issues arise.

UK

Recent UK reforms reflect a broader shift towards greater employer accountability and more structured workplace governance. This can be seen across a number of developments, including the strengthened duty to take reasonable steps to prevent workplace harassment, enhanced protections for whistleblowers, increased scrutiny of workplace culture and the proposed requirement for large employers to publish Equality Action Plans. These plans are intended to drive action on workplace gender equality, including measures to address gender pay gaps and support employees experiencing menopause.

For employers, the common theme is that having policies in place is no longer enough. Organisations are increasingly expected to demonstrate that they are taking active steps to identify and manage workplace risk, foster an appropriate workplace culture, support employees and respond to issues through fair, consistent and well-documented processes. We are also seeing Employment Tribunal claims, regulatory investigations and workplace complaints place greater focus not only on the decision reached, but on the quality of the employer's decision-making process and the effectiveness of the systems and controls underpinning it.

As expectations continue to evolve, employers should review the effectiveness of their governance, compliance and workplace culture frameworks, including those relating to whistleblowing, investigations, grievances, disciplinary processes, equality, inclusion and harassment prevention. Employers should also ensure that managers are equipped to identify risk, navigate sensitive workplace issues and make well-reasoned decisions that can withstand scrutiny.

Middle East 

Employment regulation across the GCC continues to evolve, with recent reforms in the UAE, Saudi Arabia and Qatar placing increasing emphasis on governance, compliance and regulatory oversight. While the legal frameworks differ, employers are increasingly expected not only to comply with employment laws, but also to demonstrate that workplace decisions are supported by robust internal processes, appropriate documentation and consistent decision-making.

Recent developments illustrate this trend. Qatar's new Labour Law amendments introduce mandatory conciliation for employment disputes, expand the Ministry of Labour's enforcement powers and strengthen regulatory oversight of employers. Saudi Arabia continues to enhance workplace governance through its Labour Law reforms and Implementing Regulations, while the UAE's federal and financial free zone employment regimes maintain a strong focus on documented procedures, investigations, whistleblowing and employer accountability.

For multinational employers, the challenge is ensuring that global policies on ethics, investigations, whistleblowing and compliance are capable of operating effectively within different legal systems and regulatory environments. As expectations continue to evolve, governance is becoming a key element of employment compliance rather than simply a matter of good practice.

Read our full article here

Singapore

Singapore’s employment framework is moving towards greater emphasis on internal governance and demonstrable decision-making. The upcoming Workplace Fairness Act will require employers to establish grievance-handling processes and will prohibit adverse employment decisions based on specified protected characteristics, including in recruitment, performance appraisal, promotion and dismissal.

Employers should therefore ensure that workplace decisions are supported by objective criteria, appropriate documentation and consistent processes. Grievances should be handled confidentially and escalated through clearly defined channels, while managers and decision-makers should receive appropriate training. As the regulatory focus shifts from recommended practice towards legal compliance, the ability to explain and substantiate how employment decisions were made will become increasingly important.

Hong Kong

Recent developments in employment legislation in Hong Kong reflect a broader expansion of employee protections, with employers required to update their internal employment processes to conform to the amended and newly implemented legislations. 

Hong Kong’s Employment (Amendment) Ordinance 2025, which took effect on 18 January 2026, introduces an extended definition of continuous contract, focusing on bringing in more employees under the umbrella of statutory employment. The abolition of Mandatory Provident Fund (MPF) offsetting arrangement and the rollout of the eMPF platform also reflect the government’s efforts to enhance transparency and efficiency in MPF administration. 

Multinational employers should ensure internal processes meet these new regulations. As the regulatory landscape continues to evolve, employers should regularly review workplace policies and practices to maintain compliance.

Read our full article here

Australia

Employers continue to face increased scrutiny of their workplace compliance obligations. The Federal Court’s decision in Fair Work Ombudsman v Woolworths Group Limited & Ors [2025] FCA 1092 was an important reminder of the risks associate with any organisations’ failure to meet legislative wage requirements.

At the same time, employers are adapting to significant regulatory changes, including the introduction of payday super from 1 July 2026 and proposed reforms to the Australia’s modern slavery framework, which would increase expectations on businesses to identify, manage and address labour exploitation risks within their operations and supply chains.

These developments demonstrate that payroll compliance, superannuation obligations and supply chain governance are becoming increasingly important areas of organisational risk. Employers should ensure their systems, processes and controls are fit for purpose to minimise legal, financial and reputational exposure. 

Read more in our longer article

Chile

Chile operates under a dual regime. In cases of workplace harassment, sexual harassment and violence at work, Law No. 21,643 (the "Karin Act") converted the investigation process into a statutory duty subject to a regulated procedure, requiring a written and signed record of every statement, and obliged employers to incorporate into their Internal Work Regulations a prevention protocol identifying hazards and assessing psychosocial risks with a gender perspective. Outside those specific scenarios — fraud, conflicts of interest, policy breaches — Chile has no statutory internal investigation procedure: employer action continues to rest on managerial prerogative, supported in practice by compliance programmes, internal regulations and crime prevention models. The latter cover bribery and other economic offences and were strengthened by Law No. 21,595, which now requires secure reporting channels, employee training and mandatory periodic assessments by independent third parties.

Three features of the Karin Act regime tend to surprise multinational groups. An employer may not conduct an internal investigation unless its Internal Work Regulations incorporate the legally required procedure; if they do not, the complaint must be referred immediately to the Labour Board. Where the complaint is directed against persons deemed to represent the employer, an internal investigation is prohibited and the company loses control of the case. And in subcontracting or labour supply arrangements, the obligation to investigate always falls on the principal employer or user company, including in respect of employees who are not its own.

For the multinational employer, the consequence is that global investigation policies must be adapted to fit the Chilean procedure where it applies, and not the other way around. It is advisable to ensure that the Internal Work Regulations are up to date before the first complaint arrives, to identify in advance which cases will fall outside the company's control, and to map the obligations assumed by the principal employer in relation to contractors.

Egypt

The country's new Labour Law No. 14 of 2025 which came into force on 1 September 2025 and replaced the decades old Law No. 12 of 2003 significantly raises the compliance bar for employers, introducing new anti-discrimination, anti-harassment and anti-bullying protections, tighter notification and documentation obligations. 
Also, employers must now maintain far more rigorous paper trails around hiring, contract terms, notice periods and terminations, with unlawful or undocumented dismissals exposing them to reinstatement orders or service linked compensation awards.

For multinational employers, the challenge is much the same as elsewhere in the region: global policies on ethics, investigations, whistleblowing and HR compliance need to be capable of translating into Egypt's specific procedural and documentary requirements, not simply applied generally. As Egyptian authorities move from legislative overhaul into active enforcement, governance is fast becoming a core compliance obligation for employers on the ground and not merely a matter of good practice.

Kenya

While the 2007 Employment Act remains largely unchanged, Kenyan courts continue to strengthen workplace protections for both employers and employees, with recent decisions demonstrating an increasingly practical analysis of employment disputes and structures.

The Supreme Court recently confirmed that the jurisdiction of the Employment and Labour Relations Court extended to pre-employment disputes, hence there is now definitive legal exposure for conduct during the recruitment process (see Moi Teaching and Referral Hospital & 3 others v Gikenyi & 74 others [2026] KESC 50 (KLR)).

Section 45(2) of the Employment Act requires an employer to prove both valid reason and fair procedure for termination, and courts have emphasised that compliance in one does not cure deficiencies in the other. In addition to being valid, reasons for termination must be reasonable within the circumstances. For example, circumstances that indicate double punishment are not considered valid reasons for termination since the wrong had been previously sanctioned. Procedural fairness requires strict compliance with statutory and contractual safeguards, and relatively minor missteps can taint the entire process. Courts are increasingly assessing employment hearings under the principles of fair trial. Apparent or actual bias in disciplinary proceedings are fatal, and employers are required to give an employee reasonable opportunity to prepare a defence prior to a show cause hearing.

Courts are increasingly examining the practical reality of an employment relationship rather than relying on the contract and related features. Employers can no longer preserve short-term employment status through repeated renewal of fixed-term contract where the relationship is in practice continuous. A similarly fact-sensitive approach applies when determining issues like constructive dismissal, where, as held in a recent case, an employer cannot rely on outdated system records to claim the employee was not summarily dismissed. This approach works both ways, and courts have reiterated the reciprocity of employment relationships in decisions that recognise the withholding of payment as legitimate where an employee is absent from work without authorisation.

Subject to alignment with local employment laws, employers are required to comply with their Human Resources manuals, disciplinary policies and other internal procedures. Courts enforce internal decision making, which must follow an organisation’s authorised reporting and governance structures. Additionally, courts will not obstruct legitimate workplace processes, such as lawful internal investigations or dispute resolution mechanisms, simply because an employee alleges constitutional violations.

Tanzania

Tanzania's employment law landscape has moved decisively toward stronger institutional governance since the Labour Laws (Amendments) Act, No. 4 of 2025 took effect. Employers now operate under a more structured compensation regime for unfair termination, with arbitrators required to apply defined bands depending on whether the defect lies in procedure, substance, or both, and a materially higher band where discrimination or harassment is found.

The amendments also introduce a significant procedural safeguard: once a dispute is referred to the Commission for Mediation and Arbitration or the Labour Court, employers are barred from initiating or continuing disciplinary proceedings on the same matter. Early, well documented internal handling of workplace issues has therefore become more important than ever.

For multinational employers, the practical lesson is that governance frameworks designed elsewhere in the group need to be tested against these specific procedural rules, particularly around timing, documentation and the interplay between internal disciplinary processes and CMA referral.

Read our full article on navigating Tanzania's 2025 labour law reforms and strengthening internal governance frameworks.

Takeaways 

• Move from policy to practice: Ensure governance frameworks are embedded into day-to-day operations, not simply documented.
• Strengthen internal processes: Establish clear, consistent procedures for managing workplace issues, investigations and decision-making.
• Maintain consistency with appropriate flexibility: Apply core governance principles consistently while adapting processes to meet local legal and regulatory requirements.
• Document decisions effectively: Keep accurate, contemporaneous records that demonstrate fairness, accountability and compliance.
• Invest in capability: Equip managers and key stakeholders with the knowledge and confidence to identify risk, respond appropriately and make well-informed decisions.