The following Corporate Crime guidance note provides comprehensive and up to date legal information covering:
Has your company got a clear and forthright code of ethics which explicitly refers to a zero tolerance of bribery and corruption?
This code of ethics should reflect the core values of the organisation and should have Board level approval. See precedents: Anti-bribery and corruption policy and Memorandum to board accompanying anti-bribery policy (subscription to Lexis®PSL Commercial practice area is necessary).
Is this code of ethics supported by policies? Is there top level commitment to these policies from the Board and does a senior officer of the company oversee the anti bribery policy?
Are the anti-bribery policies and procedures a Board meeting agenda item for consideration every month?
Are the details of the Board’s discussion of the anti-bribery policies and procedures fully minuted?
Is there a Board sub-committee with responsibility for overseeing the amendment and enforcement of the anti-bribery policies and procedures?
Does the company’s General Counsel and the legal/compliance department as a whole, have specific anti-bribery legislation and practice? If not, then (a) the company should retain external lawyers with the requisite knowledge; and (b) the company should consider a suitable internal training programme
Do the Board have the same anti-bribery training as other staff? The Board member(s) with responsibility for anti-bribery may need specialist training on the legislation and compliance procedures
Do the members of the Board and all
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