Bribery risk is not limited to direct payments. Intermediaries, public and private sector relationships, donations and conflicts of interest need consideration in everyday decisions.
Identify the countries, customers and authority involved. Fees, evidence of actual services and payment recipients should be understandable. Establish proportionate due diligence, contractual controls and monitoring. A separate legal entity does not automatically place the bribery risks of work performed for you outside the system.
Value is only one factor. Consider timing, the recipient's role, influence on decisions and frequency. An offer near a tender or contract decision may present different risks. Define rules, approvals and records clearly, and apply any stricter legal conditions relevant to the situation.
Consider the specific allegation and whether available information can be assessed. Anonymity alone should not justify dismissal. Establish confidentiality, protection against retaliation and review free from conflicts. Preserve evidence and limit sharing to necessary recipients. Record conclusions and any further information needed.
No. It concerns assessment of the management system within its scope, not perfect conduct in every transaction or immunity from legal responsibility. Detection, prevention, investigation and improvement must continue. The response to an allegation matters too. Do not present certification as making investigation unnecessary.
Assess customers, public sector relationships, intermediaries, payment methods, gifts and donations. A low-risk conclusion from another market does not automatically apply. Appropriate legal expertise may be needed. Assign owners and start dates for new controls, and notify the certification body of significant scope changes.
Disclose the relationship and assess the conflict first. Separation of authority, independent evaluation and clear records may be required. Apply relevant law, contracts and policy rather than assuming automatic approval or prohibition in every case. Preserve evidence of genuine competition and the services actually supplied.
Share the subject, organisation or product, target market, current evidence and target date. The team can then separate consultancy, official fees, independent evaluation and realistic timing.
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