The following Practice Compliance precedent provides comprehensive and up to date legal information covering:
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.
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.
What is an agent or intermediary?
Agents and intermediaries are third parties engaged to provide services for or on behalf of [insert organisation’s name] or represent our interests.
They may include:
third parties retained in relation to government business or actions;
lawyers and other professional advisors; or
other third parties who provide services for or on behalf of [insert organisation’s name] in any capacity.
Application of the law to agents and intermediaries and the risks they present
Bribery laws prohibit payments to agents and intermediaries knowing that all or part of the payment will be used to pay bribes.
‘Knowing’ includes more than actual knowledge—it can include:
deliberate ignorance of facts that put
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