Anti-Bribery & Corruption Due Diligence design

With the majority of bribery prosecutions resulting from the corrupt activities of third parties, it’s not surprising that anti-corruption legislation such as the UK Bribery Act, FCPA and Sapin II place considerable importance on anti-corruption due diligence.

Despite this, it remains one of the hardest anti-corruption areas to get right.  The GoodCorporation paper Combating Corruption: are businesses doing enough? revealed that almost two thirds of the due diligence procedures assessed were graded as inadequate.

GoodCorporation offers a due diligence design service which enables our clients to carry out risk-appropriate and robust due diligence on even the most complex supply chains, using a three-stage screening process to identify high, medium and low-risk third parties and the subsequent level of due diligence required.

Our due diligence design service is tailor-made to suit the needs of each organisation and includes:

  • Designing processes to ensure due diligence can be conducted proportionately (identifying the at-risk third parties) on both the ‘stock’ and ‘flow’ of third parties
  • Creating appropriate due diligence questionnaire templates
  • Developing a follow-up process to manage the responses to the questionnaires
  • Developing a clear process for identifying any red flags and putting in place appropriate mitigation measures
  • Documenting the process for appropriate record-keeping
  • Developing a monitoring system to identify what follow-on checks are needed and when
  • Advising on the use of third party screening tools

We also advise on appropriate mitigation of risks identified by the due diligence process including:

  • Use of ABC clauses in third party contracts
  • ABC training for third parties
  • Communications programmes
  • Creating forums to share best practice


Contact us for further information.