You should adopt a risk-based approach to managing bribery and corruption risks. Your procedures should be proportionate to the risks faced by your organisation. While no policies or procedures are capable of detecting and preventing all bribery and corruption, a risk-based approach will help focus the effort where it is most needed and will have most impact. The fuller the understanding of the risks an organisation faces, the more effective your efforts to prevent bribery and corruption are likely to be.
A risk-based approach usually involves five steps:
identify the risks you face
assess the risks you face
design and implement systems and controls to mitigate those risks
monitor your systems and controls
keep a record of what you have done and why you have done it
The first two steps—identifying and assessing—are...
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