Bribery Compliance

Guidance published by the UK Ministry of Justice identifies that top-level involvement in bribery prevention is likely to include: "General oversight of breaches of procedures and the provision of feedback to the board or equivalent, where appropriate, on levels of compliance".

A firm's defence to a criminal prosecution is founded on its ability to prove that despite a particular instance of bribery, it nevertheless has and maintains adequate procedures to prevent persons associated with it from bribing.


An effective anti-bribery framework includes, senior management:

  1. Ability to demonstrate effective implementation of risk-sensitive policy and procedure (e.g. via periodic compliance testing and reports of findings)
  2. Ownership and accountability (either directly or via appropriate delegation) for implementing and maintaining effective anti bribery and corruption programmes
  3. Access to timely management information on new/emerging bribery risk, in the firm's operating environment

Assurance arrangements

Senior management should ensure clarity of accountability and responsibility, for:

How we can help you

FCRM conducts UK and international reviews of client anti-bribery arrangements. On international assignments (where practicable) we use experienced personnel with knowledge of local language, anti-bribery requirements, culture and business practice.

We review policy and procedure, and deliver robust compliance testing of the application of anti-bribery policy and procedure. Reports include fact-based findings, objective commentary on internal systems and where required, practical recommendations to improve/enhance controls.

Integrity in Business Practice