Corporate hospitality is a useful tool but are you overly hospitable?

1 Your organisation

• Is your organisation incorporated/based in the UK?
• Is it part of a group of companies?
• Are any of the organisation’s parents or subsidiaries based abroad?
  
• Has the organisation faced any bribery incidents in the past? If so, what preventative measures have been
  put in place?
• Does you organisation employ agents? If so, are any based abroad?
  
• Are any countries in which the organisation operates known for bribery and corruption? If so, what is done
  to mitigate the risks?
  
• Does the organisation depend on a few high value transactions/ clients?

2 Your business

• Where is your principal area of business?
  
• Does your business involve transacting abroad?
  
• What markets/ industry does your organisation operate?
• Are any of these markets known to have bribery risks? If so, what is done to mitigate
  these risks?
  
• Are there any high value transactions which the business enters into on a regular basis?
  
• Are there any high value transactions which the business enters into as a one-off
  or irregular basis?

3 Dealing with other parties

AGENTS/ CONTRACTUAL PARTIES

• Does the organisation have an anti-bribery policy in place for agents and any party
  it contracts with?
• What procedures does the organisation have in place when selecting agents/ parties
  to contract with? Is any due diligence undertaken?
• What sanctions does the organisation impose against an agent or any party it contracts
  with if they breach the anti-bribery policy?

GOVERNMENT OFFICIALS (IN THE UK OR ABROAD)

• Does the organisation interact with public officials in its business?
• Does the organisation need any public licences to operate its business?
• Does the organisation carry out any public sector contract work?
• Have you fully trained the staff who comes into contact with such officials on the Act?

4 Your management staff

• Who is responsible for overseeing compliance within your organisation?
• Is management tiered at group, company and international level? Are all employees aware
  of who they should report to?
• Can management staff delegate their powers to others and if so, how would they be able to identify anomalies in transactions?
• Has all management staff conveyed a clear and coherent message to ensure their staff
  comply with the Act?

1 Policies

• Does your organisation have a clear and coherent anti-bribery message?
• Is there a need to create a specific anti-bribery policy for your organisation?
• Is there a policy in place on sponsorships, corporate hospitality, promotional expense
  and charitable donations? Is there a reporting requirement? Are any limits/ prohibitions
  clearly set out?
• Is there a policy in place that no facilitation payments should be made by or on behalf of the organisation?
• Has the organisation ensured that all staff has read, understood and will adhere
  to such policies? If not, what could the organisation do to ensure the relevant policies
  have been enforced?
• Has the organisation ensured that the policies have been communicated both internally
  and externally?

2 Training

• Have you provided all staff with training on the Act and consequences of breaching the Act?
• Is your training adequate? Have you considered tailored training sessions for high risk
  members of staff?
• Have you informed all staff who they should report to if they have any queries or concerns
  about the Act?

3 Financial controls

• Has the organisation ever accounted or budgeted for facilitation payments?
• Are all outgoings made by or on behalf of the organisation documented?
  Or does the organisation allow for “off book” accounting?
  
• Does the organisation regularly carry out spot checks to ensure there are no suspicious transactions? If so, who is responsible for these checks and who do they report to?

4 Employees

• Does any employee receive bonuses linked with obtaining high value or public contracts?
• Is any employees’ remuneration disproportionate to their duties?
• Are any employees provided with a disproportionate hospitality limit compared to
  their colleagues of an equal level?