Anti-Bribery & Corruption Risk Assessment

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Anti-Bribery & Corruption Risk Assessment


Bribery and corruption remain among the most damaging risks a business can face. A single incident involving a rogue employee, third-party agent, or distributor can trigger regulatory action, heavy penalties, blacklisting from tenders, and long-lasting reputational damage — often disproportionately greater than any commercial gain.

Regulators in India and globally — through laws such as the Prevention of Corruption Act, FCPA, and UK Bribery Act — increasingly hold companies accountable for the actions of their employees, vendors, and partners. Demonstrating a credible anti-bribery program is now a core expectation from regulators, lenders, investors, and multinational customers.

We help organizations identify, assess, and mitigate bribery and corruption risks through structured risk assessments, third-party due diligence, policy design, and ISO 37001-aligned frameworks — so your business remains compliant, ethical, and resilient.

Frameworks & Regulations We Align With
Prevention of Corruption Act, 1988
Companies Act, 2013
US FCPA
UK Bribery Act 2010
ISO 37001
PMLA
SEBI LODR
OECD Guidelines

Our Anti-Bribery & Corruption Services

01

ABC Risk Assessment

Structured identification and scoring of bribery and corruption risks across functions, geographies, and third parties.

02

Policy & Code Design

Drafting of ABC policy, code of conduct, gifts & hospitality policy, and conflict of interest framework.

03

Third-Party Due Diligence

Risk-based screening and due diligence of vendors, agents, distributors, consultants, and JV partners.

04

Controls Review

Evaluation of internal controls around procurement, payments, expenses, and high-risk transactions.

05

Whistleblower Framework

Design and implementation of confidential reporting channels and investigation protocols.

06

Training & Awareness

Role-based training programs, e-learnings, and workshops for leadership, employees, and third parties.

07

ABC Audit

Independent audit of ABC program design, implementation, and effectiveness against global standards.

08

Investigation Support

Forensic-led investigations into allegations, whistleblower complaints, and suspected misconduct.

Common Bribery & Corruption Risk Areas

Government Interactions

Licenses, approvals, inspections, tenders, and dealings with public officials.

Third-Party Agents

Liaison agents, consultants, and intermediaries engaging with regulators on your behalf.

Procurement & Vendors

Kickbacks, inflated invoices, vendor favoritism, and conflict of interest in purchase decisions.

Sales & Distribution

Channel incentives, tender rigging, and distributor or dealer payments.

Gifts & Hospitality

Excessive gifts, lavish entertainment, sponsored trips, and undocumented benefits.

Facilitation Payments

Small “grease” payments to speed up routine government work — prohibited under most laws.

Donations & Sponsorships

Charitable donations, political contributions, and CSR channeled for improper influence.

Recruitment & HR

Hiring of relatives of officials or clients to gain favor or influence decisions.

Our Assessment Approach

1

Scoping

Understanding business model, geographies, functions, and existing ABC framework.

2

Risk Identification

Mapping inherent bribery and corruption risks across processes and third parties.

3

Control Evaluation

Assessing the design and operating effectiveness of existing controls and policies.

4

Risk Scoring

Quantifying residual risks based on likelihood, impact, and control maturity.

5

Recommendations

Providing a prioritized action plan to strengthen the ABC framework end-to-end.

Why Anti-Bribery & Corruption Risk Assessment Matters

Comply with Indian and global anti-corruption laws
Protect the business from penalties and prosecution
Safeguard brand reputation and stakeholder trust
Meet investor, lender, and MNC due diligence expectations
Reduce third-party and supply chain risk exposure
Create a culture of ethics and accountability
Prepare for ISO 37001 certification readiness
Demonstrate “adequate procedures” legal defense

Industries We Serve

Manufacturing
Pharmaceuticals
Infrastructure
BFSI
Energy & Oil
Healthcare
IT & Services
MNC Subsidiaries

FAQs on Anti-Bribery & Corruption Risk Assessment

What is an anti-bribery & corruption (ABC) risk assessment?
An ABC risk assessment is a structured review of a company’s exposure to bribery and corruption risks across its operations, functions, geographies, and third parties. It identifies vulnerabilities, evaluates existing controls, and recommends corrective actions.
Is an ABC risk assessment mandatory?
While not always explicitly mandatory, it is strongly expected under laws like the US FCPA, UK Bribery Act, and ISO 37001. Indian companies dealing with MNCs, exporters, listed entities, and regulated sectors are increasingly required to demonstrate ABC due diligence to customers and regulators.
What laws govern bribery and corruption in India?
The key Indian laws include the Prevention of Corruption Act 1988, Companies Act 2013, Prevention of Money Laundering Act (PMLA), and SEBI LODR for listed entities. Indian companies with foreign operations or partners must also comply with FCPA and the UK Bribery Act.
Can a company be held liable for the actions of third parties?
Yes. Under most anti-bribery laws, a company can be held liable for bribes paid by its agents, consultants, distributors, or vendors, especially if there is inadequate due diligence or oversight. This makes third-party risk assessment a critical part of any ABC program.
What are facilitation payments?
Facilitation payments are small, unofficial payments made to speed up routine government actions like clearances or approvals. They are expressly prohibited under the UK Bribery Act and most other frameworks, and are treated as bribes under Indian law.
What is ISO 37001?
ISO 37001 is the international standard for Anti-Bribery Management Systems. It provides a structured framework for preventing, detecting, and addressing bribery risks. Certification demonstrates to customers, regulators, and partners that the company has robust anti-bribery controls.
How often should an ABC risk assessment be conducted?
Best practice is to conduct a comprehensive assessment every 2 to 3 years, with focused reviews annually or whenever there is a significant business change — such as entering a new geography, acquisition, new product line, or major regulatory update.
What deliverables will we receive?
You will receive a detailed risk assessment report, a heat map of key risks, a gap analysis against global standards, recommended policies and controls, a third-party risk framework, and a prioritized implementation roadmap with timelines.

Protect Your Business from Bribery & Corruption Risk

Partner with our experts to assess, strengthen, and certify your anti-bribery framework — and build a culture of integrity that stands up to any scrutiny.

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