This Flowchart is a guide for staff involved in the anti-bribery and corruption due diligence process for appointing or monitoring agent or intermediary relationships. It should be used in conjunction with our [insert, eg Anti-bribery and corruption—agents and intermediaries policy, Anti-bribery and corruption—independent evaluation and authorisation of an agent/intermediary arrangement and Anti-bribery

This Practice Note deals with agents and other intermediaries in relation to anti-bribery and corruption. It covers what an agent or intermediary is, how working with agents and intermediaries could put a commercial organisation at risk and the steps you could take to mitigate those associated risks. What is an agent or intermediary? Agents and intermediaries are third parties engaged to provide services for or on behalf of your organisation or to represent your interests. This may include: • business consultants • sales agents • third parties retained in relation to government business or actions • introducers • facilitators • lawyers and other professional advisors, and • other third parties who provide services for or on behalf of an organisation in any capacity Whether a specific third-party relationship is an agent or intermediary relationship is a matter of fact in each case. When considering what anti-bribery and corruption procedures to apply to a third-party relationship you may consider the degree to which the third party may act autonomously on behalf of your organisation in

1 General information Date of review [Insert date] Person(s) conducting review [Insert name] 2 Data Criteria In the last [insert period, eg quarter] Over the last 12 months Total number of internal suspicious activity reports (SARs) received [Insert number] [Insert number] Number of internal SARs with a bribery or corruption element [Insert number] [Insert number] Number of internal SARs with a bribery or corruption element reported to the National Crime Agency (NCA) [Insert number] [Insert number] Number of internal SARs with a bribery or corruption element reported to the NCA requiring consent [Insert number] [Insert

We run our business[es] with integrity. All of us must work together to ensure our business[es] remain[s] untainted by bribery and corruption. This form is integral to that effort. See also: Charitable and political donations policy. This form must be used in every case where a charitable or political donation requires approval. It is to be completed

This Flowchart is to be used to ensure all relevant points are considered before a charitable or political donation is approval request is granted or rejected. Notes Note 1—Legal/regulatory environment Consider the legal and regulatory environment—does the law of the territory or the regulations governing the recipient allow this sort of donation? If not, the approval request must be rejected. Note 2—Intention You should always consider the intention behind

Charitable and political donations can give rise to higher risks of bribery and corruption. They can be (or be seen to be) bribes in disguise. This Practice Note sets out what charitable and political donations are, the risks they carry and how to mitigate those risks. Charitable donations A charitable donation is a gift made by an individual or company to a non-profit organisation or charity. It can include giving or providing cash, venues, equipment, personnel time or other benefit to a charity or to an individual or organisation nominated by or connected with a charity. Although often grouped together (as they are here) charitable donations are usually very different in concept to political donations. Most charities have no connection with politics and no decision-making role or influence over procurement decisions, and so there is a lower risk that a charitable donation could be corrupt or be perceived to be corrupt. Indeed, many organisations see charitable giving as an important part of their corporate social responsibility efforts. But charitable donations do still carry risk;

We run our business[es] with integrity. All of us must work together to ensure our business[es] remain[s] untainted by bribery and corruption. This FAQ document, which is integral to that effort, guides us on how we can best achieve our business goals in a way that is consistent with our commitment to counter bribery and corruption. 1 What are charitable donations? A charitable donation is a gift made by an individual or company to a non-profit organisation or charity. A charity means any body of persons or trust established for charitable purposes only. A charitable donation can include giving or providing cash, venues, equipment, personnel time or other benefit to a charity or to an individual or organisation nominated by or connected with a charity. Most charities have no connection with politics and no decision making role or influence over procurement decisions, and so there is minimal risk that a charitable donation to them could be corrupt or perceived to be corrupt. Indeed, many organisations see charitable giving as an important part of their corporate social

1 Introduction 1.1 We run our business[es] with integrity. All of us must work together to ensure our business[es] remain[s] untainted by bribery and corruption. This policy is integral to that effort and we are all bound by it. 1.2 [Insert organisation’s name] takes pride in its support of charities and good causes and is committed to conducting itself with the highest standards of probity in continuing to offer such support. 1.3 Bribery and corruption is, however, an area where perception can sometimes be more important than fact. Corrupt payments can be disguised as charitable and political donations. Regardless of whether a donation has been made with purely innocent motives, if an external observer could put an adverse construction on that donation, it puts the business, and the person receiving the donation, at risk. 1.4 This policy contains controls to minimise this risk but we rely on staff to exercise judgement about how any donation might be perceived, recognising that what at first sight might appear to be reasonable might nevertheless become the subject of unreasonable comment or criticism by external parties.

Please click for an Excel version of this register. This Precedent charitable and political donations register forms part of an organisation’s anti-bribery and corruption measures. It is intended to record charitable and political donations made under your anti-bribery and corruption procedures and all associated

This anti-bribery and corruption Checklist is designed to help you determine whether you have the systems in place to comply with the Bribery Act 2010 (BA 2010) and government guidance relating to anti-bribery and corruption. It should be read in conjunction with subtopics: • Anti-bribery and corruption—regulatory regime • Anti-bribery and corruption—Identifying & assessing risks • Anti-bribery and corruption—policy and procedures, or for law firms, Anti-bribery and corruption—policy and procedures—law firms • Anti-bribery and corruption—gifts and hospitality • Anti-bribery and corruption—agents and intermediaries • Anti-bribery and corruption—joint ventures and acquisitions • Anti-bribery and corruption—charitable and political donations • Anti-bribery and corruption—staff training & awareness, or for law firms, Anti-bribery and corruption—staff training and awareness—law firms • Anti-bribery and corruption—monitoring and review This Checklist signposts relevant Precedents you can use or adapt to comply with these requirements and recommendations. There is a box for you to mark whether you have completed each requirement and a section to insert comments or note action points. General Requirement Compulsory or recommended Comment/action ☐ Implement a public, clear and forthright code of ethics

Bribery and corruption remain major issues in world trade, despite the many dedicated efforts to prevent them. These issues are very damaging when they occur and can (among other things): • divert money and other resources from those who need them most; • hinder economic and social development; • damage business, not least by increasing the cost of goods and services. Bribes can include cash payments, gifts, favours, any item or service of value, or any other benefit or financial advantage. Bribery can occur when anyone authorises, offers, solicits, gives, receives or accepts anything of value, or any financial or other advantage, in exchange for favourable treatment or improper performance of a function or activity by a company, government authority, official, employee or private individual. Most countries have laws prohibiting bribery and corruption. Many of these laws

We run our business[es] with integrity. All of us must work together to ensure our business[es] remain[s] untainted by bribery and corruption. This FAQ document, which is integral to that effort, guides us on how we can best achieve our business goals in a way that is consistent with our commitment to counter bribery and corruption. 1 What is a facilitation payment? A facilitation (or grease) payment is an unofficial payment made to secure or expedite the performance of routine, non-discretionary government actions. They are nominal sums typically paid to lower level public or government employees to help expedite a legitimate process that is allowed, but which might otherwise take much longer to complete. Examples include: —payments made to a public or government employee to expedite the processing of official documents such as permits, licences, certifications, visas or work orders —payments made to obtain telephone service, power or water supply, police protection, mail collection and delivery, or inspections Facilitation payments could be