Jurisdiction(s):
United Kingdom

Corporate anti-bribery compliance checklist for overseas partners and third-party intermediaries: board governance, risk-based due diligence, gifts and hospitality, facilitation payments, whistleblowing, investigations, monitoring and review

Published by a LexisNexis Corporate Crime expert

Checklists

Checklist for overseas partners on preventing bribery

Policies and procedures

Does the company have a clear, robust and practical code of ethics that expressly states zero tolerance for bribery and corruption?
Is that code backed by proportionate policies? Is there visible top-level commitment from the Board, and does a suitably experienced senior officer oversee the anti-bribery framework?
Are anti-bribery policies and procedures a standing agenda item at Board meetings?
Are the Board’s discussions on these policies and procedures comprehensively recorded in the minutes?
Is there a Board sub-committee charged with updating and enforcing the anti-bribery policies and procedures?
Do the company’s General Counsel and, where applicable, the legal/compliance team have specific expertise in anti-bribery legislation and practice? If not, (a) are external lawyers with the requisite knowledge retained; and (b) is an appropriate internal training programme considered?
Do Board members receive the same anti-bribery training as other staff?

...

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

Nicola Finnerty

Kingsley Napley

Nicola is a leading criminal defence expert in white collar and business crime, general criminal defence, and proceeds of crime and asset forfeiture.Over the last 25 years she has been involved in many of the most high-profile, complex criminal and regulatory investigations and prosecutions, both in the UK and in matters which span jurisdictions. She represents high net worth individuals, multi-national corporate clients, financial institutions and professional firms in investigations and proceedings brought by all the UK enforcement agencies including the SFO, FCA, CMA, HMRC, NCA, Food Standards Agency, the Environment Agency, the Gangmaster and Labour Abuse Authority (GLAA) and other prosecuting bodies.She routinely advises on cross border and domestic investigations across a wide range of industry sectors including financial services, construction, property, telecommunications and mining. She conducts and advises in internal investigations and is regularly appointed as an...

Web page updated on 21/05/2026

Popular documents

Using the Judicial College Guidelines to assess general damages in personal injury claims

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

Tomlin orders in England and Wales: CPR guidance on drafting, confidentiality, approval, variation, enforcement, limitation, CCA issues, court-specific requirements, sample wording and precedents

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Precedent: Deed of Surrender of Lease with Optional Premium, Settlement and Release, Landlord, Mortgagee and Guarantor Consents, Reimbursement and HM Land Registry Provisions (England and Wales)

Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

Precedent Statutory Declaration: Standard Wording under the Statutory Declarations Act 1835

I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...