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Bribery and corruption

assessment template

The Government published the first UK Anti-Corruption Plan in 2014 and in it committed to working with
experts “to publish a corruption risk assessment template for Government departments and agencies
aligned with the Cabinet Office fraud risk assessments” (see Action 17 in the Plan). A Progress update
on the UK Anti-Corruption Plan published on 12 May 2016 reported that this would be made available
on the Gov.uk website by December 2016.

No sector is immune to bribery and corruption and central Government and those it does business
with are vulnerable to the threat it poses. Employees and those associated with central Government
have significant influence and access to sensitive information ranging from state secrets through to
commercially confidential material and are at risk of being targeted by those seeking to corrupt.
For departments, organisations and individuals to protect themselves from bribery and corruption a
comprehensive understanding of the unique risks posed is essential to manage and mitigate the threat.
So too is a commitment to transparency, open government and accountability.

This bribery and corruption self-assessment template takes the user through key questions all
organisations will want to consider in order to: better understand and articulate the threat; establish the
risks faced; and assess the organisations capacity to manage and mitigate that risk. We have set out a
series of possible responses to each question accompanied by further guidance to help users identify
areas needing improvement and how to make those improvements in order to develop a more robust
approach to counter bribery and corruption activity. We also recommend summarising the current activity
within the organisation for each question and setting out next steps. Those responsible for bribery and
corruption within the organisation will be responsible for co-ordinating the completion of the form, but we
recommend that it is signed off by top level management.

Key Definitions
In this document a number of definitions are used. It is important to relate the following to your
organisation:

Bribery Bribery is defined as – offering, promising, agreeing to receive or giving of a

financial or other advantage to induce or reward improper functions or activities
and/or the request or receipt of such an advantage.
Corruption For the purposes of this document, corruption in the public sector including
Central Government can be defined as the abuse of power by an official (or any
employee entrusted to carry out the functions of government, including
contractors) for personal gain.
Fraud The term ‘Fraud’ is used to define offences contrary to the Fraud Act 2006 based
on false representation, dishonesty, financial gain or loss and associated
offences, which include bribery and money laundering.
Risk Assessment A bribery and corruption risk assessment builds a comprehensive picture of the
risks that an organisation faces, evaluates controls and evaluates the likelihood
and impact of these risks.
Threat Assessment A threat assessment considers the capability and intent of the potential harm

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Top Level Board of directors (or any other equivalent body or person)
Management

Having completed the assessment sheet, please provide an overview of where your
organisation is now in terms of the following areas:
Counter bribery and corruption culture Red Amber Green
 Top-level commitment (Q1)
 Counter bribery and corruption strategy (Q2, Q3)
 Counter Corruption Champions (Q4)
Overview

Counter bribery and corruption high level risk assessment Red Amber Green
 Bribery and corruption risk and threat assessment (Q5, Q6)
 Mitigation and ownership of risk (Q7, Q8, Q9)
 Risks for business areas, partners and suppliers (Q10, Q11, Q12, Q13)
Overview

Counter bribery and corruption procedures and tools Red Amber Green
 Tools to identify bribery and corruption activity (Q14)
 Recording bribery and corruption incidents (Q15)
 Processes to counter bribery and corruption (whistleblowing, audit etc) (Q16, Q17)
 Investigation (Q18, Q19)
 Insider threat, including gifts & hospitality registers, outsourced providers, data misuse (Q21, Q22, Q23)
Overview

Counter bribery and corruption awareness, training and Red Amber Green
communication
 Training for all staff (Q24)
 Civil Service Learning courses (Q25)
 Outsourced providers (Q26)
 Promoting guidance and reporting suspicions (Q27, Q28)
Overview

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Counter bribery and corruption culture

1. Is there top-level management commitment to countering bribery and corruption in your

organisation?
Guidance notes: The UK has demonstrated global leadership to tackle corruption by hosting the
UK Anti-Corruption Summit in May 2016. The UK government committed to a package of actions
(see all country commitments here) to tackle corruption in all its forms, including corporate secrecy
and government transparency. It is therefore crucial that the UK demonstrates it is getting its own
house in order and that there is top level commitment to tackling bribery and corruption in all central
Government departments.
Top-level Management should be committed to preventing bribery and corruption by persons
associated with the organisation and they should foster a culture within the organisation in which
bribery and corrupt activity is never acceptable.
The Cabinet Office has developed Counter Bribery and Corruption Standards (which can be found on
the Government Counter Fraud pages). These set out the standards that organisations should follow
to develop an effective response to bribery and corruption. They also identify the skills required by
individual specialists working in counter bribery and corruption for HMG, with a maturity matrix
attached to monitor and assess their capability and development.
Element Yes Developing No Don’t know
1
Commitment
Involvement2
Communication3
Statement4
Zero Tolerance5

In the space below, please provide a brief overview of current activity and future plans:

1
There should be a clear and effectively communicated commitment throughout the organisation. It should be evidenced
through statements, resourcing and embedment
2
Active involvement of the Board or equivalent with a named point of contact, ensuring that regular discussion takes place at
board level
3
Should include internal and external communications including regular updates on counter bribery and corruption issues
accessible to all those associated with the organisation
4
A statement should be published on a yearly basis which is refreshed and takes account of the changing nature of bribery
and corruption
5
Action should be taken against all breaches in bribery and corruption controls and proactive action should be taken to reduce
opportunities for bribery and corruption.

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2. Does your organisation have a current counter bribery and corruption strategy (or a Fraud
Strategy with specific corruption content)?
Guidance notes: A counter bribery and corruption strategy provides a platform for organisations
to demonstrate their commitment to tackling bribery and corruption both externally and internally.
It offers the opportunity for greater transparency both to staff and to the public more widely, and
should take into account the Counter Bribery and Corruption Standards produced by the Cabinet
Office (see Government Counter Fraud pages).
Elements to consider for a counter bribery and corruption strategy:
 Define the scope, and which parts of the organisation are / are not covered by the strategy
 Define the current challenges the business and the counter bribery and corruption function is
facing
 Define future challenges
 Demonstrate how the organisation’s fraud risk assessment feeds into the strategy
 Demonstrate key strengths and weaknesses of the organisation’s current counter bribery and
corruption provision and approach
 Clearly define future aspirational state of the counter bribery and corruption approach
 Define the time period that the strategy will cover
 Define key activities that will be undertaken to move to a future aspirational state
 Define key stakeholders (may be annexed)
 Simply and compellingly (in language appropriate to the business) categorise the actions into
areas that aid the communication of the strategy
 Define how progress against the strategy will be monitored, what the key metrics for success look
like and how the organisation will know it is being successful
 State where the delivery plan for the strategy is held (likely to be an annexed action plan).
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

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3. How is the Counter Bribery and Corruption Strategy (or relevant part of the Fraud Strategy)
implemented and communicated?
Guidance notes: it is crucial that the strategy is implemented across the organisation and that all
staff are aware of it and what it means for them. See also section on Counter Bribery and Corruption
Awareness, Training and Communication (Q24 onwards).
Element Yes Developing No Don’t know
Written strategy
Communicated internally, inductions/staff
handbook/intranet
Communicated externally, internet/
commercial activity
Governance structures in place to
support the strategy which are regularly
reviewed/monitored
Reviewed for progress by top level
management
Embedded in policies and procedures
Included in specific individuals work
objectives

In the space below, please provide a brief overview of current activity and future plans:

4. Do you have a suitably trained, senior counter corruption champion in the organisation who
promotes counter bribery and corruption messages?
Guidance notes: Organisations may benefit from having a senior counter corruption champion
(or to have countering corruption as a specific responsibility within another role, such as counter
fraud champion), responsible for promoting counter bribery and corruption messages. Audit, counter
fraud, procurement, HR and other teams will want to ensure they work closely with the champion and
each other.
The Government Anti-Corruption Champion is currently Sir Eric Pickles and his role is defined in the
UK Anti-Corruption Plan (see page 56 paragraph 8.2).
Element Yes Developing No Don’t know
Champion in place
Champion communicates regularly on
corruption issues

In the space below, please provide a brief overview of current activity and future plans:

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Counter bribery and corruption high level risk assessment

5. Do you undertake threat assessment activities to identify and assess capability and intent?
Guidance notes: The findings of the threat assessment should inform the assessment of risk, with
a focus on ‘the capabilities and intent of a person or group with the potential to cause harm to the
organisation’s objectives’. This can include an analysis of: past bribery, corruption or fraud; the skills
needed for a perpetrator to be successful in the act of bribery / corruption and the opportunities to
commit bribery / corruption in the organisation.
Some threats, for example the use of emerging technologies by third parties to commit new and
unforeseen types of bribery or corruption, may be beyond the organisation’s control. In these
circumstances, organisations should use threat-related knowledge/strategic intelligence to aid risk
prioritisation. A threat assessment should be used to inform the bribery and corruption risk
assessment (see Q6 below).
Element Yes Developing No Don’t know
Undertaken internal threat risk assessment
including individual contracts/projects
Undertaken external threat risk
assessment
Have you developed an action plan as a
result of the outcome of your threat
assessment?
Do you have a process of review?

In the space below, please provide a brief overview of current activity and future plans:

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6. Do you include the assessment of bribery and corruption risk as part of your regular risk
assessment process?
Guidance notes: The risk from bribery and corruption should be captured as part of detailed risk
assessment undertaken on individual business areas as set out in the Government Counter Fraud
Standards.
The Communications Electronics Security Group (CEGS) which is the national technical authority
for information assurance, has published some helpful guidance on managing information and risk.
The principles set out in the Ministry of Justice Bribery Act 2010 Guidance will also be of assistance.
Though the corporate failure to prevent offence under section 7 of the Bribery Act covers only
‘commercial organisations’, the Ministry of Justice Guidance is still valuable for Departments to
consider. Furthermore, though Government Departments are not ‘commercial organisations’ for the
purposes of section 7 and have crown immunity from prosecution, elements of their activities may be
deemed as commercial when they trade as a commercial entity. Individuals within Government
Departments are also criminally liable under the Bribery Act at all levels.
Element Yes Developing No Don’t know
Risk Assessments undertaken by a
suitably experienced/qualified person(s)
Bribery and corruption risks clearly
recorded in risk assessment
Taken account of country risk
Taken account of sector risk
Taken account of scope of organisation
and its supply chain

In the space below, please provide a brief overview of current activity and future plans:

7. Are risk assessments documented and accessible to appropriate persons?

Guidance notes: The outcomes of the risk assessment should be effectively communicated with
stakeholders in the organisation. This should include the development of a risk register for the
organisation, via workshops and by briefing executive boards. See Government Counter Fraud
pages for further information on risk assessment.
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

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8. How far is the organisation able to develop a clearer picture of which risks of bribery and
corruption are greatest within the organisation and those associated with it?
Guidance notes: Risks from bribery and corruption can vary between organisations and it is
important that suitably experienced staff carry out the assessment. Each organisation needs to
understand the current risks it faces from bribery and corruption and where these risks lie. To do this,
as a first step consider your assets; your vulnerabilities; who might benefit from your assets (and
why); and how they could obtain them. The UK Anti-Corruption Plan and the recent Progress Update
on the UK Anti-Corruption Plan are helpful resources, as is the Cabinet Office Fraud Risk
Assessment Standard which is available on the Government Counter Fraud pages.
Element Yes Developing No Don’t know
Top level oversight of process
Risk assessment process for bribery and
corruption is embedded throughout the
organisation
Identification and recording of risks
Evaluation of risks
Prioritisation of risks
Documented

In the space below, please provide a brief overview of current activity and future plans:

9. Do you have a regular risk assessment cycle that includes the effective mitigation of
identified risks and the assignment of ownership?
Guidance notes: Ensure that there is an area of business responsible for recording the risks for the
whole organisation and that the risks are assessed and scored consistently across the organisation.
Risks should also be shared appropriately with relevant teams in the organisation to ensure the risk
is managed and mitigated across the board.
Element Yes Developing No Don’t know
Clear owners of each risk identified
Mitigation steps and controls
implemented

In the space below, please provide a brief overview of current activity and future plans:

10. Does the organisation consider / capture bribery and corruption risks presented by those it
does business with (e.g. suppliers)?
Guidance notes: It is important to assess bribery and corruption risks arising from supply chain and
customer sources and the potential for reputational or financial damage that these risks pose.

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Though Government departments are not criminally liable under Section 7 of the Bribery Act 2010,
trading arms of departments and individuals within departments, may be considered criminally liable.
Element Yes Developing No Don’t know
Organisation includes customers/
suppliers in scope of own risk
assessment(s)
Is assured that customers/those in the
supplier chain have their own robust
processes

In the space below, please provide a brief overview of current activity and future plans:

11. Has your organisation made its key external partners aware of the bribery and corruption
risks it faces and expectations of those partners?
Guidance notes: Sharing your organisation’s understanding of its risks from bribery and corruption
will increase accountability from partners (such as private sector and non-governmental
organisations), ensure transparency and raise awareness of the risks of bribery and corruption to
both the organisation and partner organisations.
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

12. Have you considered specific areas of your business where there is a common threat from
bribery and corruption, including against relevant payment streams?
Guidance notes: In their National Strategic Assessment of Serious and Organised Crime 2016 the
NCA highlights the risk of bribery and corruption in the public sector. Criminal groups use bribery and
corruption to access sensitive information and corrupt elected officials and procurement systems for
financial gain. They also target local government to manipulate processes such as housing or
planning, and have been known to target officials in order to consolidate their status in communities.
 Procurement: This is a complex and significant area of risk for departments and the Government.
The Chartered Institute for Procurement and Supply (CIPS) has published guidance on
procurement and supply. The Competition and Markets Authority (CMA) has also produced some
helpful tools and guidance on spotting and avoiding bid-rigging in the public procurement process.
 IT and data: The Data Protection Act may be helpful when assessing when and how data can be
shared, particularly with external organisations.
 Finance: HM Treasury have related guidance available that may be helpful. Fraud and the
internal Auditor and Managing the Risk Fraud Guide for Managers.
 People: The Centre for the Protection of National Infrastructure (CPNI) has carried out extensive
research into corrupt insiders and has produced personnel security guidance and tools to help

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organisations reduce their vulnerability to the insider threat and to mitigate the risks from well-
placed insiders. Personnel security is a way in which to manage the risk of staff exploiting their
legitimate access to an organisation’s assets or premises for unauthorised purposes. Rotating
staff in key positions can for instance be effective in reducing the likelihood of bribes being
offered and accepted. Weaknesses in effective protective security and management processes
allow insiders to circumvent controls and exploit those weaknesses.
Element Yes Developing No Don’t know
Grants, loans
Commercial, procurement and contract
Information technology and data
Benefits
Administrative spend (e.g. payroll)
Capital spend (e.g. buildings, infrastructure)
Receipts (tax revenue)

In the space below, please provide a brief overview of current activity and future plans:

13. Have you considered specific areas of your business where there is a common threat from
bribery and corruption, including from the following people / business areas?
Guidance note: Other common areas to consider are those in a position of trust, for instance those
collecting taxes, fines and debt or issuing penalties or sanctions could be open to bribery.
Element Yes Developing No Don’t know
Finance
People (insider threat), particularly those
key decision makers with powers
Those with responsibility for technical
specifications
Those with responsibility for monitoring
commercial activities
Those responsible for distributing grants
Those responsible for making policy
decisions
Those responsible for making frontline
decisions on funding

In the space below, please provide a brief overview of current activity and future plans:

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Counter bribery and corruption procedures and tools

14. Do you have data analytics and data washing processes in place to better identify possible
bribery and corruption activity and/or data misuse for bribery and corruption purposes?
Guidance notes: Data washing and data analytics can be used to identify bribery and corruption.
One of the options available is the National Fraud Initiative (NFI). The NFI is an exercise that
matches electronic data within and between public and private sector bodies to prevent and detect
fraud. Information about working with the NFI including timescales, case studies and general
guidance can be found on the Gov.uk pages on the NFI.
It is important that Data Protection Act issues are considered when planning data washing activity.
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

15. Do you have a system for recording and capturing all incidents of bribery and corruption and
failures of the counter bribery and corruption management system?
Guidance notes: Organisations should ensure that they have procedures in place to capture
all instances of suspected bribery and corruption and that they are reported appropriately (or
investigated internally where an in-house investigation team exists) and followed up. Lessons
should be learned wherever possible. This may be part of the organisation’s fraud and whistleblowing
intelligence system, but if so there needs to be a mechanism to specifically identify bribery and
corruption within this.
All staff should know how to report an incident and be confident that it will be followed up. Having a
robust whistleblowing policy in place provides an avenue for staff to do this and helps to ensure that
individuals can report malpractice without fear of losing their job or other reprisal. (See Q16 below).
Element Yes Developing No Don’t know
System for recording incidents of bribery and
corruption
System for recording breaches of the counter
bribery and corruption control system
Process for reporting incidents and breaches
to top level management

In the space below, please provide a brief overview of current activity and future plans:

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16. Do you have whistleblowing arrangements in place that are readily accessible and regularly
reviewed?
Guidance notes: Having a good whistleblowing policy in place provides an important avenue of
information to help uncover bribery and corruption and reduce malpractice in organisations, ensuring
individuals can report malpractice without fear of reprisal.
The Department for Business Energy and Industrial Strategy (BEIS) has the following guidance for
employers and employees:
 Whistleblowing: Guidance for Employers and Code of Practice
 Blowing the Whistle to a Prescribed Person
Helpful information is also available from the Public Concern At Work website. CPNI also have a new
education programme “It’s OK to Say”. For further information please email: [email protected].
Reviewing the outcomes following each disclosure will help organisations to strengthen their
processes for listening and responding to employee concerns and taking remedial action if
necessary.
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

17. Do you use business processes such as audit to identify vulnerability to bribery and
corruption?
Guidance notes: Other business processes might include, for instance, safeguards in IT systems,
such as counter penetration measures.
The National Audit Office provide a series of frameworks and guides to aid organisations
self-assessment and decision making.
Yes Developing No Don’t know

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18. Do you have an agreed process for investigating allegations of bribery and corruption?
Do you have a dedicated resource for either investigating internally or for arrangements
with external investigators?
Guidance notes: Many organisations have a dedicated investigation team. Where there is no
resource it is good practice to have a named individual or team who is responsible for liaising with
external investigators. See Government Counter Fraud Investigation Standards, Counter Bribery
and Corruption Standards and Sanctions Redress and Punishment Standards on the Government
Counter Fraud pages for details.
Support and guidance on this may be sought from the Centre of Expertise in the Cabinet Office –
[email protected].
CPNI also have guidance available on their website on Investigating Employees of Concern.
Element Yes Developing No Don’t know
Case acceptance criteria for bribery and
corruption
Trained internal capability to respond to
incidents of bribery and corruption
Case management system to log allegations
An arrangement with external investigators
Plan to continually develop skills and
capability of investigators
Sanctions and Redress policy for
investigators to refer to

In the space below, please provide a brief overview of current activity and future plans:

19. Do you have an agreed process for reporting allegations of bribery and corruption?
Guidance notes: An internal process should consider how information is securely handled and that
adequate procedures are in place in accordance with the Bribery Act 2010.
External agency may include another cross government or public sector organisation including, but
not limited to, the Serious Fraud Office or law enforcement i.e. City of London Police.
Guidance on reporting can be found in the Counter Bribery and Corruption Standards
(see Government Counter Fraud pages).
Element Yes Developing No Don’t know
Process to report allegations of bribery and
corruption internally
Process to report allegations of bribery and
corruption to external agency

In the space below, please provide a brief overview of current activity and future plans:

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20. Do you have control mechanisms in place to help minimise the possibility of insider threat for
staff?
Guidance notes: Appropriate control mechanisms are dependent on the organisation’s assessed
risks. For individuals within an organisation opportunity, vulnerability and motivation are key factors
to consider in terms of assessing their bribery and corruption risk. The CPNI guidance referred to
earlier is a helpful resource for identifying and minimising the insider threat as is the CPNI risk
assessment advice. For instance through observing changes in behaviour: reluctance to take leave,
changes in life-style. You should also consider exit arrangements, agency staff arrangements, how
clear and well communicated your code of conduct is, gifts and hospitality recording (see Q21 below)
and so on in terms of insider threat.
 Recruitment: Consider vetting checks on key staff and the frequency that reviews should be
carried out. Cabinet Office have produced some helpful guidance. CPNI also have helpful
guidance on conducting pre-employment screening.
 External interests and notifiable associations: Ensure procedures are in place for gathering this
information and consider checking staff in key threat areas. You may also want to consider
comparing supplier data against staff data.
Managers should be aware of ways to identify employees who may be susceptible to bribery and
corruption. Consider whether there are any skill gaps.
Element Yes Developing No Don’t know
For recruitment
External interest/conflict of interest
Notifiable associations

In the space below, please provide a brief overview of current activity and future plans:

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21. Does your organisation have a gifts and hospitality register covering both offer and receipt,
including things offered but not accepted?
Guidance notes: Your gifts and hospitality register should include gifts offered, received and
declined. It should also record what was done with the gift if accepted and kept by the Department.
Elements of an effective gifts and hospitality register should include:
 Mandatory policy and procedures for all staff
 Line manager approval process for the authorisation of gifts or hospitality
 Clear definition of both gifts and hospitality to include offer of use of transport, accommodation
and costs to attend conferences
 Clear guidance that the acceptance of gifts or hospitality should be generally refused and only
accepted in prescribed circumstances
 Setting of a maximum financial limit for the receipt of gifts
 Guidance given when hospitality may be accepted
 Guidance on how to accept gifts where refusal would cause offence (gift not to be retained by the
staff member)
 Auditable process for the recording of both offers and acceptance of the gift or hospitality
 Process for staff to sign to say they have understood the policy on a yearly basis
 A record maintained of who offered the gift or hospitality
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

22. Does your organisation review the counter bribery and corruption procedures of outsourced
service providers?
Guidance notes: A proportionate review (depending on the nature and scale of the service) of
service providers your organisation uses may add an extra layer of protection from the risk of bribery
and corruption – for instance IT suppliers.
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

23. Do you safeguard high risk data sets from potential misuse by corrupt individuals?
Guidance notes: Loss of data that the organisation holds presents a significant threat to the
organisation and to Government as a whole, especially if it falls into the wrong hands.
What measures are in place to protect your organisation from the risk of bribery and corruption for
internal and external data sharing? For example, consider what information (and how and when that

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information) is shared. Is it shared on a need to know basis and is personal information protected?
Is there a shared understanding of what can and can’t be shared and in what circumstances?
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

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Counter bribery and corruption awareness, training and communication

24. Do training programmes address the responsibilities of all staff for the detection and
prevention of bribery and corruption for issues such as integrity of staff, security and vetting,
and HR processes, etc?
Guidance notes: The risk of bribery and corruption should feature in training programmes for all
levels of staff – the risks need to be recognised throughout the organisation including induction and
management and should be captured in the staff handbook. All staff need to be made aware of their
own responsibilities, as do contractors who should be informed of the organisation’s policy for
countering bribery and corruption. In particular, key decision-makers should be familiar with the
Statutory Guidance of the Bribery Act 2010.
It is helpful for bribery and corruption risks to be considered when new policies and procedures are
developed. The risks identified should be cascaded as part of staff training.
Element Yes Developing No Don’t know
Integrity of staff
Security and vetting
HR
Counter bribery and corruption is covered
in induction training
Counter bribery and corruption is covered
in the staff handbook
Counter bribery and corruption resources
are readily available to staff on the intranet
Key decision-makers within an
organisation are familiar with the Statutory
Guidance of the Bribery Act 2010

In the space below, please provide a brief overview of current activity and future plans:

25. Does your organisation promote the counter fraud, bribery and corruption learning available
to all Government departments on the Civil Service Learning portal?
Guidance notes: E-learning is available on the Civil Service learning portal entitled ‘Counter fraud,
bribery and corruption: all staff’ and ‘Counter fraud, bribery and corruption: managers’. It will raise
staff awareness, knowledge and understanding of the importance of tackling fraud, and of the risks
and issues in relation to bribery and corruption. It highlights the role and responsibilities everyone
has in fighting fraud and promoting an effective counter fraud culture across government.
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

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26. Do you promote awareness of bribery and corruption with your outsourced partners / supply
chain?
Element Yes Developing No Don’t know
Counter bribery and corruption
requirements are built into contracts
How to report incidents of bribery and
corruption is promoted with outsourced
partners

In the space below, please provide a brief overview of current activity and future plans:

27. Does your organisation publish and promote guidance on countering bribery and corruption
and the relevant elements of the Civil Service Code?
Guidance notes: The Civil Service Code is part of a contractual relationship, setting standards of
expected behaviour of all civil servants and a commitment to the Civil Service core values of:
integrity, honesty, objectivity and impartiality.
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

28. Do you communicate/raise awareness of bribery and corruption within your organisation and
the channels available to report suspicions?
Guidance notes: Consider how your organisation raises awareness of bribery and corruption and
how messages can be reinforced to enable staff to be better aware of the risks of bribery and
corruption within their work area/role.
Yes Developing No Don’t know

In the space below, please provide a brief overview of current activity and future plans:

OFFICIAL SENSITIVE [WHEN COMPLETED] 18