BRIBERY RISK ASSESSMENT FORM
Consider each question, then rate the degree of risk and insert the score in the right-hand column.
Add each score to determine the Company’s potential risk / exposure to bribery
Score 1 = Low Risk, 2 = Some Risk, 3 = Medium Risk,
Score
4 = High Risk, 5 = Very High Risk
1. Country Risk
1.1 Does the organisation operate mostly in the UK? If yes, give low score.
Does the organisation operate mostly in the UK, Europe, and US? If yes, give
1.2 low score.
Does the country in which the organisation operates or will operate have
1.3 perceived high levels of corruption? If yes, score high. Refer to Transparency
International website for objective and detailed assessments.
Has the organisation recently acquired or merged with any organisations in
1.4 countries with perceived high levels of corruption? If yes , score high. Refer to
Transparency International website for objective and detailed assessments.
Does the country in which activity is taking place or is proposed have
1.5
effectively implemented anti-bribery legislation? If yes, give low score.
Does the country in which activity is taking place or is proposed have effective
1.6 procurement and investment policies by the local government and agencies? If
yes, give low score.
2. Sector Risk
Is the proposed activity within an industry sector at risk of bribery practices?
For example:
· large-scale infrastructure such as transport or public projects;
2.1
· oil/gas/mining industries; or
· construction/property development.
If yes, give high score.
3. Transaction Risk
3.1 Does the transaction involve charitable donations? If yes, give high score.
3.2 Does the transaction involve political donations? If yes, give high score.
Does the transaction involve licences, permits and transactions relating to
3.3 public procurement which brings employees and others into frequent contact
with public officials? If yes, give high score.
4. Opportunity Risk
Does the project involve a number of contractors and intermediaries? If yes,
4.1
give high score.
4.2 Does the project involve below-market prices? If yes, give high score.
4.3 Does the project involve a tendering exercise? If yes, give high score.
5. Partnership Risk
Will the proposed activity involve the potential use of intermediaries in
5.1
transactions with foreign public officials? If yes, give high score.
Is there a risk of relationships with politically sensitive persons where the
5.2 proposed relationship involves or is linked to prominent public officials? If yes,
give high score.
6. Perceived Pressure at Work
How many employees does the organisation employ? Score -
· 1 point for one to five employees
· 2 points for six to 30 employees
6.1
· 3 points for 31 to 99 employees
· 4 points for 100 to 499 employees
· 5 points for 500 or more employees
What is the organisation's turnover? Score -
· 1 point for up to £100,000
· 2 points for up to £250,000
6.2
· 3 points for up to £500,000
· 4 points for up to £1m
· 5 points for more than £1m
Is there a robust and clear anti-bribery policy in place within the organisation? If
6.3
no, score high.
Has the organisation’s anti-bribery policy been communicated at all levels? If
6.4
no, score high.
Is there a board member or senior manager appointed to take responsibility for
6.5
all anti-bribery measures within the organisation? If no, score high.
Are there robust internal financial controls in place to monitor all payments and
6.6
transactions? If no, score high.
Are there clear policies in place in relation to hospitality, entertainment,
6.7 promotional expenditure and expenses? If no, score high.
Total score (out of a possible 110) 0
Scoring Assessment:
A score of 67 to 110 indicates a high risk of bribery. Immediate steps need to be taken to
counter the high risk and probability of bribery occurring. In certain cases, it may be necessary to
stop certain operations or transactions occurring. The organisation will need to take urgent action in
relation to specific high-risk areas identified above.
A score of 45 to 66 indicates a medium risk of bribery. A full anti-bribery policy needs to be in
place and training rolled out at all levels. Such training should be given to employees and associated
persons, including agents, consultants and temporary workers working on behalf of the organisation
in the UK and overseas. Leadership is required from the Board to ensure full engagement and
compliance. The organisation should ensure that clear reporting mechanisms are in place so that
suspected bribery may be immediately dealt with. Specific high-risk areas identified above should be
dealt with at the highest levels, preferably by board members as an urgent priority.
A score of 22 to 44 indicates a low risk of bribery. Where there is a low risk on the basis of the
risk factors identified above, steps will be taken to ensure that there are adequate procedures in
place to counter bribery. This may include a written policy that is available to all employees and
associated persons working on behalf of the organisation and regular audits of key financial
processes, including expenses and hospitality. The organisation should keep its risk assessment
under review and take appropriate steps should a bribery risk emerge.
Information on global corruption can be found at Transparency International -
[Link]
