Anti-bribery and corruption—agents and intermediaries policyInsert date
Anti-bribery and corruption—agents and intermediaries policyInsert date

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

  • Anti-bribery and corruption—agents and intermediaries policyInsert date
  • Appendix 1UK agent/intermediary due diligence form
  • Appendix 2Overseas agent/intermediary due diligence form
  • Appendix 3Due diligence questionnaire for agent/intermediary
  • Appendix 4Evaluation and authorisation of an agent/intermediary arrangement

From: [Insert name and job title].

We run our business[es] with integrity. All of us must work together to ensure our business[es] [remains OR remain] untainted by bribery and corruption[ and other financial crime, eg facilitation of tax evasion]. This policy is integral to that effort and we are all bound by it.

  1. 1

    Introduction

    1. 1.1

      This policy covers the use of agents and intermediaries who help with our business. It sets out the due diligence steps required before and during the engagement of an agent or intermediary to ensure the use of such an agent or intermediary does not improperly affect our business.

    2. 1.2

      What is an agent or intermediary?

      1. 1.2.1

        Agents and intermediaries are third parties engaged to provide services for or on behalf of [insert organisation’s name] or represent our interests.

      2. 1.2.2

        They may include:

        1. (a)

          business consultants

        2. (b)

          sales agents

        3. (c)

          third parties retained in relation to government business or actions

        4. (d)

          introducers

        5. (e)

          facilitators

        6. (f)

          lawyers and other professional advisors, or

        7. (g)

          other third parties who provide services for or on behalf of [insert organisation’s name] in any capacity

    3. 1.3

      Application of the law to agents and intermediaries and