Anti-bribery and corruption—monitoring, reviewing and evaluating your procedures
Anti-bribery and corruption—monitoring, reviewing and evaluating your procedures

The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:

  • Anti-bribery and corruption—monitoring, reviewing and evaluating your procedures
  • Importance of monitoring systems
  • Design
  • Reporting findings

The MoJ guidance on the procedures' commercial organisations should put in place to prevent bribery is crafted around six principles. The principles are not prescriptive; they are intended to be flexible and outcome focussed. Bribery prevention procedures should be proportionate to risk of bribery faced by the organisation. Once in place, these procedures should be monitored, reviewed and evaluated. This is reinforced by MoJ principle 6—Monitoring and review.

This Practice Note discusses some of the ways organisations can monitor, review and evaluate their anti-bribery and corruption procedures.

Importance of monitoring systems

Effective monitoring and review is critical to the long-term sustainability of an organisation’s anti-bribery programme and to its ability to demonstrate adequate operating procedures.

Principle 6 of the MoJ Guidance provides that organisations should monitor and review procedures designed to prevent bribery and make improvements where necessary.

The bribery risks a commercial organisation faces may change over time, as may the nature and scale of its activities, so the procedures required to mitigate those risks are also likely to change.

Design

Organisations should consider how to monitor and evaluate the effectiveness of their bribery prevention procedures and adapt them where necessary.

In addition to regular routine monitoring, reviews may be triggered by, eg:

  1. changes in the law

  2. governmental

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