Anti-bribery and corruption policy and procedure planning and implementation timetable
Anti-bribery and corruption policy and procedure planning and implementation timetable

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

  • Anti-bribery and corruption policy and procedure planning and implementation timetable
  • Planning phase
  • Note 1
  • Note 2
  • Note 3
  • Reporting system
  • Implementation phase
  • Note 4
  • Note 5
  • Monitoring and reviewing your anti-bribery and corruption procedures
  • more

This Precedent sets out a typical timetable for implementing an anti-bribery policy and procedure and provides examples of common phases and critical events.

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Planning phase

Note 1

The risk assessment should produce detailed recommendations for any required remediation of the organisation’s anti-bribery and compliance program.

For more guidance, see subtopic: Identifying & assessing risks and particularly Practice Note: Key risk areas—bribery and corruption. See also Precedent: Bribery and corruption—risk assessment.

Note 2

Precedent Anti-bribery and corruption policy will help you with this stage of the process. See Precedents: Anti-bribery and corruption policy—for law firms and Anti-bribery and corruption policy.

In preparing your organisation’s anti bribery and corruption policy, keep in mind:

  1. what are the specific outcomes you are seeking to achieve?

  2. how will the policy be monitored and enforced?

  3. how has your organisation handled anti-bribery and corruption in the past?

  4. is it future proof?

For more guidance, see Practice Note: Anti-bribery—adequate procedures (or, for law firms) and Precedent: Anti-bribery and corruption policy—for law firms or Anti-bribery and corruption policy.

You should secure the approval of senior management before proceeding any further. See Precedent: Memorandum to board accompanying anti-bribery policy.

Note 3

For more guidance, see Practice Notes: Anti-bribery and corruption—gifts and hospitality, Anti-bribery and corruption—agents and intermediari