Due Diligence Checklist: A Step-by-Step Guide to Managing Third-Party Bribery and Corruption Risk in 2023

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Companies operating in today’s global business environment must navigate ever-strengthening anti-bribery and corruption regulations. Some of the most significant recent enforcement actions against companies arose from alleged due diligence failures, leading to fines, legal action, strategic risks and reputational damage. Meanwhile, there are growing expectations around companies’ understanding of their Environmental, Social and Governance (ESG) impact, including new legislation mandating them to carry out human rights and environmental due diligence. All this should prompt companies to carry out effective supply chain due diligence to mitigate bribery & corruption, modern slavery and wider ethical conduct risks. 

A due diligence checklist takes you step-by-step through the information you need to consider to help carry out a thorough investigation when you’re contemplating a new commercial relationship, a prospective business partner or monitoring an existing one. Some checklists offer a narrowly defined area of application. This is suitable if you are preparing for a business takeover or a real estate transaction, but inappropriate for your own business as it stands. 

Other due diligence checklists take a more extensive approach but turn out not to cover all you need to surface the relevant risks. Rather than focusing on either a narrow or broad scope, our checklist includes questions aligned to situational risks to help you determine the level of third-party due diligence investigation required to mitigate risk. Our checklist also recognizes that regulatory requirements change, so it highlights some of the key laws against foreign bribery at time of posting and suggests how companies can remain compliant.

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