Policy Smoke Grenades
When too many policies signal more danger than discipline.
Are too many policies an indicator of risk?
No, of course not.
But also, maybe.
Paper Over Practice
In this case, the documents belonged to an agribusiness spanning everything from upstream distribution of crops to downstream fertiliser supply.
The risks were extensive, conflict and post-conflict zones, regulatory minefields, and the fact that fertiliser can double as a bomb ingredient.
So, sure, many policies might simply reflect scale and complexity.
But what disconcerted me was the dissonance between them.
The bribery policy, written eight years ago, promised a risk assessment that never materialised.
The KYC framework ignored sanctions entirely.
The fraud policy wasn’t reflected in training.
So far, so normal.
I’m used to seeing organisations that grew quickly, often with donor or impact investor support, patch together compliance systems like a “prison homebrew.”
A Bank XYZ KYC template glued to a local law firm’s take on sanctions, with a few post-its of “context.”
Something Didn’t Sit Right
But this was different.
The real concern wasn’t the paperwork itself, but how the company handled legitimate due diligence requests.
Instead of clear answers, there was a data room carpet-bombing, a deluge of documents dumped all at once, followed by silence behind a consortium lead.
That structure (common in syndicated loans, co-investments, or insurance deals) can make sense: one point of contact handling all the questions.
But when it blocks access to the people actually doing the work, not just the paper shufflers, it’s a red flag.
The Jiu-Jitsu Parallel
On Saturday, after jiu-jitsu, I had coffee with a classmate, a cop of 30 years, who wanted some career advice.
We talked about how hard it is to train people to spot deception, risk, or anomalies.
His team attends endless workshops, yet some still miss glaring red flags.
We discussed whether that’s paralysis by analysis, inexperience, underconfidence, or just instinct.
It’s like the jiu-jitsu class we’d just come from: some people grasp it fast; others take ages; most tap out.
(Only 10% of those who start ever reach their first belt.)
After half a century of combined risk experience, we agreed:
At some point, you must rely on instinct.
It’s there for a reason.
The Little Voice
Think of every bad decision you’ve instantly regretted.
Was there a nagging doubt, a little voice?
That’s instinct, the evolutionary radar that’s kept us alive this long.
And on this project, my instinct was on red alert.
So I did some digging.
Through my network, I found other investors who had looked at the company, without the consortium lead blocker, and walked away.
Why?
Because those policies were paper tigers.
Enforcement: weak.
ESG team: under-qualified, under-resourced, and powerless.
Past due diligence: unearthed fraud, regulatory conflicts, and geopolitical tripwires.
Humans Still Have the Edge
No matter how advanced our systems get, including everyone’s favourite career-killer, AI, they lack curiosity and instinct.
We’re not replaceable. Not yet.
But here’s the bigger question:
If you voiced your instinct today, would your leadership support you — or hit you with a policy smoke grenade?
Hurry, While Stocks Last
If you missed the launch of the Business Integrity Toolkit, co-authored by TI Sweden, Swedfund, and Ethics Insight, don’t worry.
The sessions were recorded, one is live on the TI website (and our homepage).
That page also includes a short form to register your interest in a workshop covering due diligence, risk assessment, or action plans.
A Note on Scarcity
There’s a classic marketing trick, “Hurry while stocks last… only three left!”
I’ve always found that dubious.
But, in this case, it’s true.
I only have capacity to run a handful (3–5) of these sessions for the rest of the quarter.
And registering interest doesn’t guarantee a slot, there needs to be a good fit and confidence I can actually help.
So, if you’re interested…
Hurry while my brain still works.
Contextual Quote for the Week
“Life is like music, it must be composed by ear, feeling and instinct, not by rule.
Nevertheless, one had better know the rules, for they sometimes guide in doubtful cases, though not often.”
— Paracelsus
Need More?
Find out why the world’s most ethical investors say I’m “particularly skilled at sensitively engaging with firm leadership on very tricky topics.”
Why SMEs we’ve screened as potential investments thank us for “the deep thoughtful approach.”
And why Transparency International said:
“We wholeheartedly recommend Rupert for his creativity, inventiveness, and professionalism - a definite 10 out of 10,”
after a recent collaboration.
Plus: free assessments, guides on integrity risk and sustainability, two chapters of my book, and how to schedule a no-obligation strategy session.
👉 Get More