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06) Does your organisation have a policy to manage conflicts of interest relevant to anti-bribery and corruption?

August 19, 2021
Financial Risk
Anti-bribery and Corruption

Answer yes if your organisation has a policy to manage conflicts of interest. The policy should provide a framework and instructions that outline when and how an employee should report any conflicts of interest. Please upload the policy (as a PDF file) as evidence. Please check our knowledgebase to review this control's applicability to your organisation.

It is illegal to offer, promise, give, request, agree, receive or accept bribes - an anti-bribery policy can help protect your business. All companies should have one. This control looks specifically at whether the policy includes a process for managing conflicts of interest.

You should have an anti-bribery policy if there is a risk that someone who works for you or on your behalf might be exposed to bribery.

Your anti-bribery policy should be appropriate to the level of risk your business faces. Your policy should include:

  • your approach to reducing and controlling the risks of bribery;
  • rules about accepting gifts, hospitality or donations;
  • guidance on how to conduct your business, eg negotiating contracts;
  • rules on avoiding or stopping conflicts of interest.

Once you have an anti-bribery policy you should:

  • tell your staff and make sure they understand the policy;
  • monitor and review your policy regularly.

How to implement the control

The UK government have some good guidance on how to comply with anti-bribery and corruption law. This can be found here.

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