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.