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
Featured Case Study
Building an ABC Due Diligence process
Anti-corruption due diligence has proved to be the hardest anti-bribery practice for companies to implement. Based on our findings from over 50 assessments, the GoodCorporation White Paper Combating Corruption: are businesses doing enough? revealed that…Read more