Global Business Integrity Solutions

We are your partner to develop or enhance your compliance program and risk management competencies to strengthen your culture of integrity and governance.



Penalties from regulators worldwide, resulting from anti-bribery law violations are staggering. Corporate enforcement actions by the US DOJ/SEC have soared within the last 12 months.

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Your compliance program: “iPhone 4” or “iPhone 11”

The level of integrity, quality of policies and procedures as well as laws and regulations are key factors, which influence an organization’s culture and overall business conduct.

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Understanding and managing risks as an integral part of your day-to-day business activities is imperative in order to achieve the operational and strategic goals of your company.

In today’s fast changing business world static risk management methodologies, bureaucratic control systems and formalistic compliance programs are no longer suitable to successfully steer your business while properly responding to the various expectations and regulations of your business environment.

At STEER we believe in risk management as a dynamic element of doing business built on a solid framework and an integral part of the management process at the same time.

At STEER we believe in controls embedded in your business processes and organizational culture that allow operating effectively and efficiently while safeguarding assets and resources at the same time.

At STEER we believe in high ethical standards based on solid compliance programs while at the same time being part of an organization’s culture of integrity.

With many years of experience we have learned the keys to develop strong methodologies and processes in the fields of Compliance, Risk Management, Internal Control Systems and Audit work. We have experienced the challenges to make them become part of a company’s “DNA”. We are looking forward sharing our experiences with you. It’s never too late to come on board!

What We Offer

We assist companies achieving a culture of integrity and strong governance, globally

Internal Audit functions or elements

Why do we see the same audit findings over and over again?

“Internal Auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization’s operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes” (IIA - Institute of Internal Auditors).

According to the above definition the audit activities are also designed to add value by improving an organization’s operation. Whenever the question “Why do we see the same audit findings over and over again” is raised, it demonstrates that the expectations at least partially have not been met.
A typical audit finding describes a control weakness and in addition a recommendation for improvement might be offered. The most important question however is what needs to happen so that the same audit finding will not come up again in future. The answer to this question directs us to the organization’s underlying principles and systems, its values and culture and capability to learn.

Steer’s consultancy aims at building or strengthening Internal Audit functions (or elements thereof) in a way to provide independent, objective assurance while at the same time helping to strengthen the organization by providing recommendations for improvement, based on pragmatic solutions that are designed to become an integral part of an organization’s processes.

Corporate Monitoring Services

One of the US Department of Justice’s (DOJ’s) missions is to ensure the integrity of business organizations and protect the public from corporate corruption. Compliance must be a priority for companies facing anti-corruption challenges and companies who have invested in effective compliance programs to prevent and detect potential violations will receive significant consideration and meaningful benefits from DOJ.

DOJ has increasingly employed the tools of Deferred Prosecution Agreements (DPA’s) and Non-Prosecution Agreements (NPA’s), and has recognized the benefits to companies of assigning an independent monitor or Corporate Compliance Consultant (CCC) to oversee implementation of a DPA or NPA. DPAs/NPAs are a method for federal prosecutors to impose penalties and internal reforms on companies without subjecting them to the consequences of a criminal conviction.

A monitor/CCC is not retained to reinvestigate the matter nor provide legal advice to the company, but is there to observe, test, report and recommend. More specifically, monitors review and test the company's accounting, information management, and internal control functions.

The monitor is not an agent of the Government or the corporation. The primary role of the monitor/CCC is to oversee the company’s compliance with the settlement agreement and the implementation of compliance program enhancements to prevent future violations of the law. The selection of a corporate monitor/CCC is a shared responsibility between the violating company and the government.

If performed effectively the monitor/CCC is also an opportunity to enhance a company’s compliance program, trainings, audit and compliance check ups and improve agent and distributor controls.

STEER offers monitoring/CCC services for companies who are in a DPA or NPA as a result of an FCPA violation, based on global experience in the field of monitoring and implementing ‘state-of-the-art’ compliance programs, which have been acknowledged as such by DOJ.

STEER brings a practical, experienced, hands-on approach to this monitoring process and work through geographical, cultural or industry challenges, supporting and guiding the company.

We bring to the company a cost effective, proven methodology to achieve a successful conclusion to a DPA, utilizing our extensive experience and ability to promote cooperation in all levels of the corporation and maintain oversight and accountability.

Governance roles and responsibilities
  • Organizational development with regard to the Company’s system of internal control (COSO standards)

Who We Are

Your Partner for Global Business Integrity Solutions.

We are a boutique consulting firm consisting of professionals with many years of experience in the Senior Management of multinational environments. Our high quality performance has been honored by the management and boards of several companies, as well as by authorities and regulators worldwide. We are supported by a global network of senior consultants, who perform services under our direct management.

Daniel Bleeker

25 years of experience working in Finance, HR, Audit and Legal & Integrity for two “big four” consultancy firms and a globally leading power and automation technology company

  • Has lived in Europe, USA and Middle East/Asia and performed services on all continents in over 65 countries. Established a Global Investigation Unit, and assisted in the development of a state of the art Compliance Program, acknowledged by the US Department of Justice.
  • Managed investigations into Code of Conduct breaches, including fraud, self-enrichment and allegations of FCPA violations.
Kerry Keating

Over 40 years of working experience in three Fortune 500 companies in Corporate Security, HR, and Legal & Integrity.

  • Extensive experience in building and implementing comprehensive corporate compliance/integrity programs for multinational companies to include Code of Conduct, Corporate Directives, Employee Training, Global Whistleblower Programs and Internal Investigations.
  • Extensive experience with successfully enhancing existing Corporate Compliance Program in response to government FCPA Sanctions/ Deferred Prosecution Agreements (“DPA”).
  • Has lived in USA and Europe and performed services on all continents in over 70 countries.
Markus Kistler

Over 25 years in various Senior Management roles in Finance, Controlling, Auditing and Compliance.

  • Chief Audit Executive in one of the world’s largest Power and Automation Companies. Successfully steered the company towards its first Sarbanes Oxley Act certification
  • Held the position of CFO of a large multinational company in China, and was Director of the Swiss-Chinese Chamber of Commerce in Beijing
  • Held the position of CFO of a 5 BUSD division in a multinational company
  • Built a state-of-the-art global audit function in an emerging market company.
  • Has lived in Europe and Asia and performed services on all continents in over 70 countries, with a focus on Asia.

Our Partners





PECB North America


Where We Start

Circumstances that might lead to your desire to strengthen your existing compliance and/or audit practices

  • forced by authorities and regulators,
  • triggered by growth path expansion into new business segments or geographical markets,
  • understanding that state-of-the-art governance is a competitive advantage.

Contact us

Get ready to start your journey. We steer.

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Correspondence addresses

Bahnhofstrasse 52, 8001, Zurich, Switzerland
14 Wall Street, 20th Floor, Manhattan, 10005, New York, United States

Office telephone
+41 44 214 62 74 (Zurich, Switzerland)
+1 860 313 8498 (New York, USA)

Daniel Bleeker

Kerry Keating

Markus Kistler

Legal Info

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Bahnhofstrasse 52
PO Box
8001 Zurich

Phone +41 44 214 62 74


14 Wall Street, 20th Floor, Manhattan
10005, New York
United States

Phone +1 860 313 8498


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