Transparency International UK | Global Anti-Bribary Guidance | GPE – October 10, 2017:
Chapter 12 – Extract: Third parties can represent a considerable bribery risk for companies. They may not operate to the standards of the company and can be used by corrupt employees as channels for bribery.
Intermediaries, in particular, are high risk; many of the largest settled case have involved intermediaries
paying bribes to public officials.
Key Elements: (Quick Read Section)
- Integrate: Develop and implement a risk based, integrated and consistent approach to antibribery management of third parties across the company’s operations. Clearly assign responsibilities for each stage of the company’s relationship with its third parties.
- Due Diligence: Collect, analyse and store relevant information about all your third parties, including their ownership, how they operate, their integrity and anti-corruption standards and any significant bribery and corruption risks.
- Be systematic: Apply a comprehensive and consistent approach to registering, conducting due diligence on and appointing third parties and to the management and monitoring of the relationship.
- Focus on your highest risks: Based on risk assessments, categorise and segment your third parties by risk. Focus your due diligence and other anti-bribery efforts on the highest risk third parties.
- Build trust and constructive relationships: Aim to develop an environment in which integrity can be fostered and bribery countered.
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