Indicators of bribery and corruption
Indicators of bribery and corruption

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

  • Indicators of bribery and corruption
  • General
  • Payments and invoicing
  • Processes
  • Contract negotiations

You do not have to behave like a police officer but you do have to remain alert to the warning signs of bribery and corruption and make the sort of enquiries a reasonable person (with the same qualifications, knowledge and experience as you) would make.

This Practice Note identifies typical warning signs of bribery and corruption which would normally require further investigation. These factors do not automatically mean that bribery and corruption is taking place—they are merely red flags. However, you should pay particular attention to matters where a number of these factors are present.

General

There has been a change in the behaviour of employees, intermediaries or business partners, eg:

  1. there's an employee within your organisation who does not take time off for sickness or holidays, or insists on dealing with specific customers/clients themselves

  2. there's an employee who has a lavish lifestyle which is not commensurate with their salary or what you know of their financial circumstances

  3. an employee has made unexpected or illogical decisions to engage third party suppliers and/or agents (for example, where there is no sufficient business need to do so), in tendering for particular projects, or agreeing to enter into particular contracts

Lavish gifts or hospitality have been provided to employees of your organisation or

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