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Bribery & Corruption indicators

Bribery & Corruption

Bribery & Corruption indicators

This list is provided by the Serious Fraud Office (SFO) and is not exhaustive as the ingenuity of those involved in corruption knows no bounds!

  • Abnormal cash payments
  • Expense payments made in round sums or excessive for role
  • Pressure exerted for payments to be made urgently or ahead of schedule
  • Payments being made through 3rd party country, e.g. goods or services supplied to country 'A' but payment is being made, usually to shell company in country 'B'
  • Abnormally high commission percentage being paid to a particular broker. This may be split into 2 accounts for the same broker, often in different jurisdictions
  • Private meetings with public contractors or companies hoping to tender for contracts
  • Lavish gifts being received
  • Individual never takes time off even if ill, or holidays, or insists on dealing with specific contractors him/herself.
  • Making unexpected or illogical decisions accepting projects or contracts.
  • Unusually smooth process of cases where individual does not have the expected level of knowledge or expertise.
  • Abusing decision process or delegated powers in specific cases.
  • Agreeing contracts not favourable to the organisation either with terms or time period.
  • Unexplained preference for certain contractors during tendering period.
  • Avoidance of independent checks on tendering or contracting processes.
  • Raising barriers around specific roles or departments which are key in the tendering/contracting process.
  • Bypassing normal tendering/contractor’s procedure.
  • Invoices being agreed in excess of contract without reasonable cause.
  • Missing documents or records regarding meetings or decisions.
  • Company procedures or guidelines not being followed.
  • The payment of, or making funds available for high value expenses or school fees etc. on behalf of others.
  • Agents or other third parties do not want our employees to be present at negotiations or interactions with officials.