We offer a range of compliance services that can help you interpret these principles into practical measures appropriate for your business.

The six principles covered by the Ministry of Justice guidance can be summarised as follows:

Proportionate procedures

Bribery prevention procedures should be:

• Proportionate to the risks faced and the size and complexity of the business
• Clear, practical, accessible, properly implemented and enforced

Top-level commitment

Top-level management should:

• Take responsibility at the board level for bribery prevention
• Foster a zero-tolerance culture toward bribery

Risk assessment

The risk assessment should:

• Consider both internal and external risks
• Be performed periodically and documented

Due diligence

Due diligence should be:

• Conducted on parties performing services for or on behalf of a business
• Proportionate and risk-based

Communication

Communication and training:

• Should ensure that bribery prevention policies and procedures are embedded and understood throughout the business
• May include external communication and a secure, confidential and accessible “speak up” procedure

Monitoring and review

Regular monitoring and review should:

• Evaluate the effectiveness of current bribery prevention procedures
• Identify and implement necessary improvements

We offer a range of compliance services that can help you interpret these principles into practical measures appropriate for your business.