Anti-Bribery Compliance Check Template – Free Word Download

Introduction

Corruption is one of the most significant risks facing global projects today. Beyond the moral imperative to conduct business ethically, the legal and financial consequences of bribery are catastrophic. Regulations such as the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the OECD Anti-Bribery Convention have extraterritorial reach. This means that a project manager in Brazil, working for a company headquartered in London, can be prosecuted in the UK for a bribe paid to a local official in São Paulo. The penalties include unlimited fines, debarment from public contracts, and prison sentences for individuals.

The Anti-Bribery Compliance Check (ABCC) is a specialized governance tool designed to prevent these violations before they occur. While general compliance reviews look at broad legal adherence, this document focuses exclusively on the high-risk intersections where money meets influence. It is particularly critical for projects involving government contracts, permits, customs clearance, or operations in jurisdictions with a high risk of corruption.

This template is designed to help the project team identify “Red Flags” early. It scrutinizes third-party relationships (where 90% of bribery cases originate), gifts and hospitality, and interactions with State-Owned Enterprises (SOEs). It moves beyond simple “checkbox compliance” to interrogate the substance of transactions. For example, asking not just “Do we have a contract?” but “Does the fee match the value of services rendered?”

Completing this checklist is mandatory for any project operating in high-risk zones or industries (such as construction, extraction, and defense). It serves as your defensive shield, demonstrating that the organization took “adequate procedures” to prevent corruption.

Section 1: Project Profile and Jurisdictional Risk

1.1 Project Metadata

Instructions:

Establish the baseline context. The location and nature of the project define the inherent risk level.

• Project Name: [Enter Name]
• Project Code: [Enter ID]
• Project Manager: [Name]
• Project Sponsor: [Executive Owner]
• Date of Assessment: [Date]

1.2 Geographic Risk Assessment

Instructions:

Corruption risk varies significantly by country. Use reputable external indices like Transparency International’s Corruption Perceptions Index (CPI) or the TRACE Matrix to assess the risk of the countries where the project operates.

Table 1.1: Country Risk Matrix

Country of Operation	CPI Score (0-100)	Risk Level	Required Due Diligence Level
Example: Denmark	90 (Very Clean)	Low	Standard Screening
Example: Nigeria	24 (High Risk)	High	Enhanced Due Diligence (EDD)
[Insert Country]	[Insert Score]	[Low/Med/High]	[Standard / Enhanced]

Guidance:

If the project operates in a “High Risk” jurisdiction (typically a CPI score below 50), this entire document must be reviewed by the Legal/Compliance Department. You cannot self-approve high-risk projects.

1.3 Sector Risk Profile

Instructions:

Certain industries are more prone to bribery due to the heavy reliance on government licenses and large capital expenditures.

• Industry Sector: [e.g., Construction, Oil & Gas, Pharma, Defense, Telecommunications]
• Inherent Risk: [High/Medium/Low]
• Justification: [e.g., “Construction requires dozens of permits from local municipalities, creating multiple opportunities for solicitation of bribes.”]

Section 2: Interaction with Public Officials

Instructions:

The definition of a “Public Official” in anti-bribery law is extremely broad. It includes not just politicians, but also employees of State-Owned Enterprises (SOEs), doctors in public hospitals, and professors in public universities.

2.1 Identification of Public Officials

Instructions:

List all points of contact with government entities.

Table 2.1: Government Touchpoints

Government Entity / SOE	Purpose of Interaction	Frequency	Primary Contact Person
Example: Port Authority	Customs clearance for imported equipment.	Weekly	Customs Agent
Example: National Oil Company	Client (Contract Owner).	Daily	Project Director
Example: City Planning Dept	Zoning permits.	One-off	City Clerk

2.2 Risk of Improper Influence

• Question: Will the project team be negotiating directly with these officials regarding approvals, fines, or tax liabilities?
• Risk Mitigation: [e.g., “All negotiations regarding fines must be conducted by the Legal Department, not the local project manager. No cash settlements allowed.”]

2.3 “Revolving Door” Checks

• Question: Does the project employ any former government officials or their close family members?
• Risk: Hiring a government official’s relative in exchange for a contract award is a common bribery scheme.
• Declaration: [Confirm that all hiring has followed standard HR merit-based protocols.]

Section 3: Third-Party Intermediaries (TPIs)

Instructions:

This is the single most critical section. Most companies do not pay bribes directly; they pay a “consultant” or “agent” who then pays the bribe. You are legally responsible for the actions of your agents.

3.1 Intermediary Inventory

Instructions:

List all agents, distributors, customs brokers, and visa expediters.

Table 3.1: Third-Party Risk Log

Third Party Name	Role	Compensation Structure	Risk Level
Example: Global Logistics Ltd	Customs Broker	Fixed Fee per container	Medium
Example: Mr. Smith Consulting	Business Development Agent	Success Fee (Commission)	Critical (High Risk)

Guidance:

“Success Fees” or large commissions are massive red flags. If an agent only gets paid if they win the contract, they are highly motivated to bribe someone to ensure the win.

3.2 Due Diligence Confirmation (Know Your Partner)

Instructions:

For every high-risk third party, confirm the following checks were done.

• [ ] Beneficial Ownership: Do we know who really owns this company? (Ensure it is not a government official hiding behind a shell company).
• [ ] Reputation Check: Have we searched for adverse media mentions or past corruption scandals?
• [ ] Capability Check: Does this consultant actually have the staff and expertise to do the work? (Or is it a “sham” contract?).
• [ ] Code of Conduct: Has the third party signed our Supplier Code of Conduct, explicitly agreeing to anti-bribery clauses?

3.3 Red Flags in Third-Party Relations

Check any that apply. If checked, STOP and investigate.

• [ ] The third party requests payment in cash or bearer bonds.
• [ ] The third party requests payment to a bank account in a different country (e.g., an agent in Nigeria asking for payment to a Swiss account).
• [ ] The third party refuses to disclose their ownership structure.
• [ ] The third party has close family ties to a key government decision-maker.
• [ ] The third party invoices for vague services like “Problem Solving” or “Relationship Management.”

Section 4: Gifts, Hospitality, and Entertainment (GHE)

Instructions:

Bribery often starts small. A nice dinner turns into a vacation, which turns into a cash payment. This section sets the boundaries.

4.1 Policy Limits

• Standard Limit: [e.g., $100 per person per event].
• Approval Threshold: [Any expense over $100 requires written approval from the Compliance Officer].
• Frequency Cap: [No more than 3 events per year for the same recipient].

4.2 Proposed GHE Activities

Instructions:

List any planned entertainment for clients or officials.

Table 4.1: Hospitality Registry

Recipient (Name/Role)	Description (e.g., Dinner, Golf)	Estimated Cost	Business Purpose	Approved?
Minister of Energy	Site visit lunch	$25 pp	Working lunch during inspection	Yes
Procurement Director	VIP Tickets to Formula 1	$2,000	Relationship building	NO (Rejected)

Guidance:

The “Proportionate” Rule: Hospitality must be proportionate to the business occasion. A sandwich lunch during a meeting is fine. A week-long trip to Las Vegas is not.

4.3 Travel and Lodging for Officials

• Scenario: Sometimes we must pay for a client to visit our factory for a legitimate inspection.
• Rule: We pay the hotel and airline directly. We never give cash to the official to book their own travel. No “Per Diems” (cash allowances) unless legally mandated and documented.

Section 5: Charitable and Political Contributions

Instructions:

Bribes can be disguised as donations to a charity favored by a politician.

5.1 Charitable Donations

• Proposed Donations: [List any community investments or CSR initiatives linked to this project.]
• Recipient Vetting: [Is the charity a legitimate registered NGO? Is it connected to a government official?]
  • Example of Risk: The Mayor asks you to donate $50,000 to his wife’s “Foundation for Arts” before he signs your permit. This is a bribe.

5.2 Political Contributions

• Policy Statement: [Most companies prohibit political contributions entirely.]
• Confirmation: “The project budget contains zero funds for political parties, candidates, or lobbying groups.” [Confirm: Yes/No]

Section 6: Facilitation Payments (“Grease Payments”)

Instructions:

A facilitation payment is a small bribe paid to a low-level official to speed up a routine non-discretionary action (e.g., $20 to get the telephone connected faster).

• Legal Status: Illegal under the UK Bribery Act. Technically allowed under US FCPA only under very narrow circumstances, but banned by almost all multinational corporate policies.

6.1 Policy Position

• Statement: “This project strictly prohibits facilitation payments. We do not pay to ‘speed things up’.”

6.2 Managing Extortion Risk

• Scenario: A customs officer refuses to release perishable goods unless paid $100 cash.
• Action Plan:
  1. Refuse the payment politely (“I cannot pay this; my company will fire me”).
  2. Ask for an official receipt.
  3. Ask to speak to a supervisor.
  4. Safety Exception: If the employee’s physical safety or health is threatened, pay the money, get to safety, and report it immediately as an “Extortion Payment” (not a bribe).

Section 7: Financial Controls and Record Keeping

Instructions:

Bribery requires off-the-books money. Strong financial controls prevent the creation of “Slush Funds.”

7.1 Petty Cash Controls

• Risk: Petty cash is the easiest way to hide small bribes.
• Control:
  • Limit petty cash float to [e.g., $500].
  • Require receipts for every single transaction.
  • Audits: Conduct surprise cash counts monthly.

7.2 Invoice Review

• Requirement: Accounts Payable must verify that services were actually performed before paying invoices.
• Check: Verify that “Consulting Fees” are supported by timesheets and deliverables (reports), not just a generic invoice.

7.3 Accuracy of Books and Records

• Legal Requirement: Hiding a bribe as a “Marketing Expense” is a separate crime (Books and Records violation).
• Declaration: “All expenses will be recorded accurately in the General Ledger with sufficient detail to identify the nature of the transaction.”

Section 8: Training and Awareness

Instructions:

Have the people on the ground been trained?

8.1 Training Status

Table 8.1: Training Log

Role	Required Training	Completion Status
Project Manager	Advanced Anti-Corruption Workshop	Completed
Sales Team	ABAC Sales Scenarios	Completed
Site Supervisors	Handling Extortion Requests	Pending

8.2 Whistleblower Access

• Communication: Have all team members (including contractors) been given the phone number/email for the anonymous Ethics Hotline?
• Posters: Are “Speak Up” posters displayed in the project office in the local language?

Section 9: Specific High-Risk Scenarios

Instructions:

Evaluate if any of these specific high-risk situations apply to your project.

9.1 Offset Obligations

• Definition: Governments sometimes require foreign investors to invest in local businesses as part of a defense or infrastructure deal.
• Risk: The “local business” we are forced to invest in might be owned by the General’s son.
• Control: All Offset partners undergo the same due diligence as TPIs.

9.2 Joint Ventures (JV)

• Risk: If our JV partner pays a bribe, we can be held liable.
• Control: We must have the right to audit the JV’s books. We must insist the JV adopts our compliance standards (or standards equally strict).

Section 10: Declaration and Sign-Off

Instructions:

This document serves as a legal attestation of due diligence.

10.1 Project Manager Declaration

“I confirm that I have assessed the bribery risks associated with this project. I verify that due diligence has been performed on all third parties and that no ‘Red Flags’ remain unresolved. I commit to enforcing a zero-tolerance policy towards corruption.”

• Name: ___________________________
• Signature: ________________________
• Date: _____________________________

10.2 Regional Compliance Officer Approval

“I have reviewed the risk profile and the proposed controls. I find them adequate to mitigate the risk of bribery to an acceptable level.”

• Name: ___________________________
• Signature: ________________________
• Date: _____________________________

Conclusion – Anti-Bribery Compliance Check Template – Free Word Download

The Anti-Bribery Compliance Check is not just paperwork; it is a mechanism for protection. In many jurisdictions, having a “compliance program on paper” is not enough to avoid prosecution. Authorities look for evidence that the program is effective, monitored, and real.

This document provides that evidence. It demonstrates that you asked the hard questions about your agents, that you scrutinized your travel expenses, and that you refused to engage in shady deals. It protects the Project Manager from personal liability and protects the company’s license to operate.

Corruption is often justified by the phrase “that’s just how business is done here.” This document is your tool to reply: “That may be true, but that is not how we do business here.” By maintaining this standard, you ensure the project’s legacy is one of integrity and sustainable success, rather than scandal and legal peril.

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Meta Description:

A specialized Anti-Bribery Compliance Check template to identify corruption risks, screen third parties, manage gifts/hospitality, and ensure adherence to FCPA/UK Bribery Act.

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