External Reviews: Transparency international

External Reviews

The use of third parties can make a valuable contribution for any organisation. But agents pose a unique corruption threat as they may be authorised to act on behalf of the company, often with a high level of discretion and minimal oversight.

Third Parties

Agents and Intermediaries

Does the company have a clear policy on the use of agents?

Does the company conduct risk-based anti-bribery and corruption due diligence when engaging or re-engaging its agents or intermediaries?

Does the company aim to establish the ultimate beneficial ownership of its agents and intermediaries?

Does the company’s anti-bribery and corruption policy apply to agents and intermediaries acting for or on behalf of the company, and does it require anti-bribery and corruption clauses in its contracts with these parties?

Does the company ensure that its incentive schemes for agents are designed in such a way that they promote ethical behaviour and discourage corrupt practices?

Does the company publish details of all agents contracted to act with and on behalf of the company?

Does the company publish high-level results from incident investigations and sanctions applied?

Joint Ventures

Does the company conduct risk-based anti-bribery and corruption due diligence when entering into and operating in joint ventures?

Does the company commit to incorporating anti-bribery and corruption policies and procedures in all of its joint venture relationships, and does it require anti-bribery and corruption clauses in its contract with joint venture partners?

Does the company commit to take an active role in preventing bribery and corruption in all of its joint ventures?