Anti-bribery—overseas agent/intermediary due diligence form

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

  • Anti-bribery—overseas agent/intermediary due diligence form

Anti-bribery—overseas agent/intermediary due diligence form

To be completed by [insert name of organisation appointing the agent/intermediary].

    1. 1

      Geographical factors

      Consider where the agent or intermediary is based.

      Country where the agent or intermediary is based[Insert country]
      Country’s Transparency International Corruption Perceptions Index score[Insert score]
      Is there any substantial basis to believe that business in the country is frequently obtained by bribing officials and/or that such payments are common?
      If yes, provide details, including how you were made aware of such information, such as from other multinational organisations doing business in the country, local contacts, periodicals or news articles
      ☐ Yes
      [Insert details]
      ☐ No
      Have enquiries been made as to the relevant civil/criminal law of the particular country to identify any significant differences to UK law (eg legality of facilitation payments)?
      If no, provide details
      ☐ Yes
      ☐ No
      [Insert details]
      Is that country known or reasonably suspected to:
      1. operate high-levels of secrecy

      2. be used as a tax shelter

      3. not subscribe to Common Reporting Standards

      4. have a low OECD tax transparency rating


      If yes, provide details
      ☐ Yes
      [Insert details]
      ☐ No
    1. 2

      General

      General details.

      Why do we need to engage an agent or intermediary?[Insert reason]
      Name of prospective third party[Insert name]
      Principal contactName: [Insert name]
      Title: [insert title]
      Contact details: [Insert contact details]
      Principal address[Insert address]
      Have we worked with this third party before?
      If yes, provide details, including in what capacity and dates
      ☐ Yes
      [Insert details]
      ☐ No
      Is the

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