EHS Audits With Empathy

In the first of a short series of articles on approaches to our work in EHS and Sustainability consulting, we're thrilled to feature insights from our global experts, starting with Lauri Niemelä from DGE Finland. Discover how empathy and curiosity transform EHS audits into more human-centered experiences. Stay tuned for more inspiring stories on sustainability and environmental approaches to our work.

*The full original article is published with DGE on LinkedIn here.

Within DGE Finland and more broadly, there has been an ongoing discussion on what defines our approach to working with both clients and target sites during audits, especially internal audits. The closest definition I could come up with is "auditing with empathy." Let me explain.

Let's not pretend we know it all

In the world of consulting, it’s easy to fall into the trap of feeling like one has to know everything. Especially in high-stakes projects it can be tempting to walk in with a checklist and a false sense of certainty.

But in reality, no one knows a business or a site as well as the people dedicating large parts of their life to whatever it is that we audit. That’s something we remind ourselves often. As consultants, we come in with technical knowledge, legal frameworks, and experience from many sectors. But we’re also outsiders. And we believe that the best audits and assessments happen when we combine our external perspective with the target sites or organization’s internal expertise, through real dialogue and curiosity.

Whether we’re reviewing permitting documentation or walking through an operational process on site, our role isn’t to outshine anyone. It’s to understand, ask pertinent questions, and offer value based on cooperation—not control.

What do we mean by “Auditing with Empathy”

Auditing with empathy is not about being soft or going easy. It’s about approaching a client or a site with curiosity and respect. It means asking questions that show we’re there to understand, not to catch anyone out. The best questions are often the open-ended ones that give our clients or our target sites the opportunity to create their own narrative. This gives us an understanding of how the representatives on site handle the topics we are reviewing.

The answers to open-ended questions also offer invaluable contextual information on potential non-compliances. They give us tips on how the gaps could be closed or explain how or why the reviewed site or company might be operating according to the intent of the laws, policies or guidance, despite not ticking a particular box, or vice versa. Such questions might include, for example, the following:

• “Can you walk me through how you handle X?”
• “What’s been working well for you lately?”
• “What’s something you've flagged but haven’t had the time or support to fix? What would be needed to close these gaps?”
• “Are there any internal practices that go beyond what’s required—but you feel are worth keeping?”
• “What part of process X do you find most frustrating or unclear?”
• "What’s something you wish more consultants and 3rd parties understood about your work?”
• “If there were no time or budget limits, what would you improve first?”

Listen First

These questions aren’t just for conversation’s sake: they help us understand the "why" behind the "what". They open up space for people to reflect, clarify, and even suggest improvements themselves. Auditing with empathy means we listen first. We understand that procedures don’t exist in a vacuum—they’re shaped by real people, real constraints, and real knowledge. When you listen well, you don’t just find gaps, you understand why those gaps exist.

This approach also pays off in very practical ways. It reduces misunderstandings during audits. It brings up small but important issues early before they become major blockers. And perhaps most importantly, it means fewer surprises for everyone involved. When people feel heard, they’re more open: we’re not only dealing with procedures and legislation, but also real people with real feelings, thoughts, opinions and rationalizations, even when these rationalizations might be problematic. When processes are understood in context, solutions come faster.

In the best-case scenarios, solutions to problems and gaps are presented by the site representatives during the audit. In the end, audits go more smoothly. Not because we lowered the bar, but because we built a stronger foundation for trust and clarity.

We often work in the middle of corporate headquarters and local sites: thus clear communication is essential for building trust and supporting the operations at the site. When we approach our target representatives as human beings, we get contextual information that can provide explanations on why an approach might be justified, even if it is not compliant at first sight, or how the big problems could be solved.

Checklists and Frameworks are Tools - not the Only Truth

All of us in the industry work with frameworks. We use checklists. They're helpful. But here's the problem: when you treat a checklist like a sacred document instead of a tool, you risk missing the point entirely. Most compliance questions aren’t simple yes/no boxes, unless we're working with very strict frameworks.

Finnish environmental legislation, for example, provides structure—but it also leaves room for interpretation, which can sometimes be very confusing for our international clients and which we often need to provide quite a bit of context on. That’s not a flaw; it’s how the system accommodates complexity. Authorities make decisions not just based on hard rules, but also on precedent, policy priorities, and even local differences in enforcement and interpretation of the legislation.

That’s where legal insight becomes essential. One of our strengths as a team is that we bring strong legal and regulatory understanding alongside scientific and field-based experience. We’re not just ticking boxes—we’re interpreting the intent behind them. We're asking: What is this regulation trying to achieve, and how does it apply in this specific case?

So yes, we’ll use a checklist. But we’ll also ask the questions behind the questions.

Compliance Isn’t Always Enough

One of the things we pay close attention to in our work is whether a company is not just technically compliant but also aligned with the intent of the law.

Because here’s the truth: it’s possible to meet all the formal requirements on paper—and still operate in a way that undermines the goals of a regulation or a guidance. This might mean exploiting grey areas, doing the bare minimum, or interpreting legislation in a way that sidesteps its purpose. From a risk management point of view, this is shortsighted. Authorities, stakeholders, and communities are increasingly alert to this gap between “compliant” and “responsible.”

Sooner or later, that gap becomes a liability; whether reputational, legal, or operational. This is where legal expertise is essential—not just for knowing what the law says, but understanding what it was intended to achieve. What was this regulation designed to prevent or promote? How do authorities interpret it in practice? What’s the expectation behind the text?

Good consultants—and good companies—ask those questions.

This Isn’t Just a Philosophy—It’s a Practice

We know that this approach works because we’ve seen the results. We’ve seen teams open up when they realize we’re not there to point fingers. We’ve seen how a deeper understanding of legislation leads to smarter and safer decisions.

We’ve received positive feedback not because we know every detail of every sector, but because we manage projects thoughtfully and build real working relationships. Empathy doesn’t replace expertise—it sharpens it. Especially when your team includes legal, scientific, and field-level perspectives, as ours does.

We choose to work this way: with openness, with realism, and with a healthy respect for the complexity of the organization we’re trying to help improve. When we're working with living, breathing human beings, empathy is not just a fluffy word or an unattainable ideal: it is requirement for gaining deep insights.

Looking for support with local EHS audits or across borders with multiple sites? Find out more about our EHS audit services here!

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