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proportionate procedures - key note

A commercial organisation's procedures to prevent bribery by persons associated with it should be proportionate to the bribery risks it faces and to the nature, scale and complexity of the commercial organisation's activities.*

(*adapted from the UK Ministry of Justice, Guidance on the Bribery Act 2010)

Of the companies surveyed just over seventy percent confirmed that they have an anti-bribery compliance programme. Of those that have a compliance programme less than half are very confident that their controls identify and mitigate bribery and corruption risks. Companies with an anti-bribery compliance programme as well as a dedicated anti-bribery policy also reported fewer incidents of bribery as opposed to those without. With less than a third feeling they were well prepared to respond to a regulatory probe.

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