You do not have to behave like a police officer, but you do have to remain alert to the warning signs of bribery and corruption and make the sort of enquiries a reasonable person (with the same qualifications, knowledge and experience as you) would make. This Practice Note identifies typical warning signs of bribery and corruption which would normally require further investigation. It incorporates examples from Wolfsberg Anti-Bribery and Corruption (ABC) Compliance Programme Guidance and guidance from the International Foreign Bribery Taskforce (IFBT). These factors do not automatically mean that bribery and corruption is taking place—they are merely red flags. However, you should pay particular attention to matters where a number of these factors are present. These indicators may be evident during various business activities, including intermediary engagement, business acquisition or general business activity, gifts and entertainment, charitable contributions, among others. General • There has been a change in the behaviour of employees, intermediaries or business partners, eg: ◦ there’s an employee within your organisation who does not take time off for sickness or holidays, or insists on