Managing the Risk of Bribery and Corruption
Procedures adopted by an organisation to counter bribery and corruption risk should be proportionate to its
level of risk. Procedures may be either stand-alone or part of wider guidance, for example on procurement,
and should include measures already in place to strengthen governance and accountability and address
wider fraud risks.
Good Practice Y/N Action Required
This organisation has a formal policy which
highlights a zero tolerance of bribery and
This organisation has anti-bribery and corruption
procedures which are proportionate to the risks
identiﬁed and the size and complexity of the
This organisation has procedures in place for
raising and reinforcing awareness, particularly with
those open to greater risk of bribery and corruption.
This organisation has sound system controls in
place which will help reduce the risk of bribery
and corruption, such as separation of duties and
delegated authority levels.
This organisation has sound ﬁnancial controls in
place which will help reduce the risk of bribery and
corruption, such as transparent accounting records
and a requirement for full supporting documentation
for all transactions.
This organisation seeks to minimise or avoid the use
of cash payments.
This organisation has strong internal and external
audit functions and an effective audit committee.
This organisation has a comprehensive set of
policies in place which address possible bribery
and corruption risks, for example conﬂicts of
interest, gifts and hospitality and anti-fraud policies.
This organisation has clear and effective procedures
in place for those wishing to raise concerns about
actual or potential bribery or corruption.
This organisation has effective procedures in place
for dealing with any bribery or corruption detected,
e.g. a fraud or bribery response plan.