For a UK construction firm, GoodCorporation was asked to undertake a desktop review of its adequate procedures to prevent corruption. Having taken the decision to self-report to the SFO, the client was keen to demonstrate that it had a strong ABC programme in place, but needed to do this in a very short period of time.
GoodCorporation therefore undertook a desktop review, lasting one week, to evaluate the client’s adequate procedures against the GoodCorporation ABC Framework. A number of gaps in the client’s policies and procedures were identified and presented to the client’s lawyers and the SFO. An action plan was agreed with the SFO and a stronger ABC programme was put in place demonstrating the client’s commitment to embedding good practice. As a result, the SFO decided to drop its investigation into the client’s affairs.