Anti Bribery And Corruption Risk Assessment Template for England and Wales

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Anti Bribery And Corruption Risk Assessment Template

Need an Anti Bribery And Corruption Risk Assessment Template for our UK-based pharmaceutical company expanding into Southeast Asian markets in March 2025, with particular focus on third-party distributor relationships and healthcare professional interactions.

Document background
The Anti Bribery And Corruption Risk Assessment Template is designed to help organizations comply with their obligations under the UK Bribery Act 2010 and related legislation in England and Wales. This document is essential for organizations seeking to demonstrate adequate procedures to prevent bribery and corruption, as required by Section 7 of the Act. It provides a systematic approach to identifying and assessing bribery risks, evaluating control effectiveness, and documenting findings for regulatory compliance. The template is particularly valuable for organizations operating in high-risk sectors or jurisdictions, supporting both initial assessments and ongoing monitoring requirements.
Suggested Sections

1. Risk Assessment Overview: Purpose, scope, and methodology of the assessment, including assessment frequency and responsible parties

2. Company Profile: Detailed information about business operations, locations, industry sectors, and organizational structure relevant to bribery risk

3. Risk Categories: Comprehensive identification and analysis of key risk areas including geographical, sectoral, transactional, and business partnership risks

4. Risk Evaluation Matrix: Detailed scoring system and methodology for evaluating likelihood and impact of identified risks, including risk tolerance levels

5. Control Framework Assessment: Evaluation of existing anti-bribery controls, their effectiveness, and gaps in the current control environment

Optional Sections

1. Industry-Specific Risks: Detailed assessment of risks specific to particular industries or sectors, including common risk scenarios and mitigation strategies

2. Third Party Due Diligence: Comprehensive assessment framework for evaluating and monitoring third-party relationships and associated bribery risks

3. Cross-Border Activities: Assessment of risks associated with international operations, including country-specific risk factors and compliance requirements

Suggested Schedules

1. Schedule 1 - Risk Register: Detailed log of all identified risks, their ratings, control measures, and risk owners

2. Schedule 2 - Control Testing Results: Documentation of control effectiveness testing, including methodology, findings, and recommendations

3. Schedule 3 - Action Plan Template: Framework for documenting and tracking remedial actions for identified gaps and risks

4. Schedule 4 - Assessment Questionnaire: Standardized set of questions used in the risk assessment process, including scoring criteria

5. Schedule 5 - Regulatory Requirements Checklist: Comprehensive checklist of compliance requirements under relevant anti-bribery legislation and regulations

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions
Clauses
Industries

UK Bribery Act 2010: Primary UK legislation governing bribery and corruption. Key sections include: offering/giving bribes (S.1), receiving/accepting bribes (S.2), bribing foreign officials (S.6), corporate failure to prevent bribery (S.7), and guidance for prevention (S.9)

Ministry of Justice Guidance: Official guidance document published by the Ministry of Justice providing interpretation and implementation guidelines for the Bribery Act 2010

FCA Regulations: Financial Conduct Authority regulations and guidance relating to anti-bribery and corruption controls in financial services sector

SFO Guidance: Serious Fraud Office policies and guidance on investigation and prosecution of bribery and corruption cases

OECD Anti-Bribery Convention: International convention establishing legally binding standards to criminalize bribery of foreign public officials in international business transactions

UN Convention Against Corruption: International legal framework addressing prevention, criminalization, international cooperation, and asset recovery in corruption cases

ISO 37001: International standard specifying requirements and providing guidance for establishing, implementing, maintaining an anti-bribery management system

Proceeds of Crime Act 2002: UK legislation dealing with confiscation of proceeds from crime, money laundering, and associated matters

Money Laundering Regulations 2017: UK regulations setting out requirements for systems and controls to prevent money laundering and terrorist financing

Criminal Finances Act 2017: UK legislation addressing tax evasion and recovery of proceeds of crime, including corporate offences of failing to prevent tax evasion

Companies Act 2006: UK legislation governing company operations, including corporate governance requirements and disclosure obligations relevant to anti-bribery compliance

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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