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Anti Bribery Risk Assessment

This document discusses risk assessment related to corruption and bribery. It provides a probability scoring matrix to assess the likelihood of corruption on a scale of 1 to 5. It also provides a potential impact scoring matrix to assess the level of impact on reputation, finances, legal/compliance, customers, and employees. The document discusses complexity factors and stakeholders involved. It outlines a heat map to visualize risk level and provides examples of bribery schemes related to various business activities like bidding, gifts, procurement, and working with partners/suppliers.

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Misha Singh
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0% found this document useful (0 votes)
862 views15 pages

Anti Bribery Risk Assessment

This document discusses risk assessment related to corruption and bribery. It provides a probability scoring matrix to assess the likelihood of corruption on a scale of 1 to 5. It also provides a potential impact scoring matrix to assess the level of impact on reputation, finances, legal/compliance, customers, and employees. The document discusses complexity factors and stakeholders involved. It outlines a heat map to visualize risk level and provides examples of bribery schemes related to various business activities like bidding, gifts, procurement, and working with partners/suppliers.

Uploaded by

Misha Singh
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as XLSX, PDF, TXT or read online on Scribd

Content

Risk Assessment - Probability & Impact


Risk Response
Mitigation & treatment Plan
Document Change Information

Probability Scoring Matrix

Status of Acual Case(s)


Probability Rating Quantitative
of the Scheme

Root cause of incident


Very low probability has been remediated
1 <10% chance (reducing the chance of
of corruption activity
repeat occurrence).
Root cause of incident is
Little probability in the process of
2 10%–25% chance
of corruption activity be_x0002_ing
remediated.
Incident has been
Some probability of contained.
3 26%–50% chance
corruption activity

Incident is in the
Considerable probability pro_x0002_cess of being
4 51%–75% chance
of corruption activity contained.
Incident has been
Very high probability re_x0002_ported and is
5 > 75% chance currently under
of corruption activity
investigation.

Potential Impact Scoring Matrix

Potential Impact Rating Reputation Financia

Minimal local media Financial impact is < 5%


atten_x0002_tion quickly of select_x0002_ed
Insignificant Impact 1
contained, short term budget item (e.g.,
recoverability. revenue or income).

Financial impact is
Local market impact on between 5% and 10% of
Minor Impact 2 Department’s brand and selected budget item
reputation. (e.g., rev_x0002_enue or
income)

Financial impact is
Sustained local press between 10% and 20%
Moderate Impact 3 coverage with escalating of selected budget item
customer implications. (e.g., rev_x0002_enue or
income).
Financial impact is
National or sustained
between 20% and 30%
regional press coverage
Major Impact 4 of selected budget item
with long-term damage
(e.g., rev_x0002_enue or
to public image.
income).

Financial impact is >


30% of selected budget
Catastrophic Impact 5 Global Media Coverage. item (e.g.,
rev_x0002_enue or
income).

Heat Map
Complexity

Very difficult to
per_x0002_petrate even
without controls place.

Difficult to perpetrate
even without controls in
place
Moderately complex to
perpetrate without
controls in place.
Easy to perpetrate
without controls in place

Very easy to perpetrate


without controls in place

Stakeholders – Stakeholders –
Legal / Compliance
Customers Employees
Notice of violation/
Minimal Insignificant impact on
warnings requiring
custom_x0002_er ___ Department’s ability
administrative action and
complaints and recovery to recruit and retain
minimal
costs em_x0002_ployees.
penal_x0002_ties
Routine governing body
litigations
Minimal decline in Some impact on
sub_x0002_ject to
customer ___Depart_x0002_ment’
moderate fines and
re_x0002_lationships s ability to recruit and
penalties may be subject
and some recovery retain
to regulatory
costs. employ_x0002_ees
proceedings and/or
hearings.

Routine litigation subject


Loss or decline of Significant impact on ___
to substantial fines or
customer relationships Department’s ability to
penalties, subject to
and moderate recovery recruit and retain top
regulatory proceedings
costs. performers.
and/or hearings.
Potentially a
signifi_x0002_cant
governing body scrutiny,
investiga_x0002_tions Strained key customer
subject to substantial relationships and Major impact on
fines and penalties, significant recovery costs ___Department’s ability
which may include some and threat to future to recruit top performers
criminal charges, subject growth.
to regulatory
proceed_x0002_ings
and/or hearings.

Major scrutiny,
inves_x0002_tigations
subject to substantial
Loss of major customer Sustained impact on ___
fines and penalties
rela_x0002_tionships Department’s ability to
including criminal
and serious threat to recruit and retain top
charges, and/or cease-
future growth. performers
and-de_x0002_sist
orders, possible
regulatory action.
Participants:

Anti Bribery Risk Assessment

S.No. Activity Risk Factor Bribery Scheme

Bribery through gifts and


1 Bidding for a public contract
hospitality.

Facilitaion payments for


2 Sales and marketing auditors, Customer
representatives

Payment to Customer under


Procurement and contracting
Dures

Payment to Suppliers under


Project management
duress

payments made to recover


funds, avoid taxation, Fines &
duties.

Payments made to avoid


litigation or government
intervention

Payment to Contractor under


dures

Gifts to Customers for Order


4 Gifts and hospitality
taking
Gift to Auditor to change the
audit decision

Facilitaion payments without


any approvals &
authorizations

Gift taken from Vendor &


Contractots for favors

Gifts present to partner


5 Working with Partner Organization
organization for doing favors

Gifts present from partner


organization for doing favors

Gifts to the Suppliers &


Working with Suppliers, contractors
6 contractors for favor in Product
and other third parties
& services

Gifts & Finacial help from the


supplies & contractors to
finlaise the Orders

Gifts & Finacial help from the


7 7. Procurement supplies & contractors to
finlaise the Orders

Gifts to the taxtaion officers to


release the materials

Benefits to Bidding of Scrap


Contractors
Note: Any Risk having score 16 or
more then 16 will be identified as
Significant Risk
Document No
Reviwed On
Approved By

Inherent Risk Rating

Impact Potential Risk Anti Bribery Controls


Probability
Impact Score
Level (1-5) Level (1-5)
1. No cash payment to any
supplier or contractor.
2. Due diligence Audit
Company reputation 3.Trainings to Employees
1 3 3
damage 4. Periodic Internal Audits

Anti Corruption Compliance


Violation of the committee ( Ethics committee
reputation and formed) for monitoring of
2 3 6
damage to company Compliance of system.
image
Heavy paneltines to Anti Corruption trainings to
company ( under the employees
1 3 3
Regulatory/ Criminal
Act)
1. No cash payment to any
Loss of Profits to supplier or contractor.
1 3 3
company 2. Due diligence Audit
3.Trainings
1. No cash to Employees
payment to any
Loss of Profits to 4. Periodic Internal Audits
supplier or contractor.
2 3 6
company 2. Due diligence Audit
3.Trainings
1. No cash to Employees
payment to any
4. Periodic Internal Audits
supplier or contractor.
2. Due diligence Audit
Loss of Profits to 3.Trainings to Employees
5. Anti Corruption
2 3 6
company ComplianceInternal
4. Periodic programAudits

5. Anti Corruption
Compliance program

1. Due diligence Audit


5. Anti Corruption
2.Trainings to Employees
Loss of Profits to Compliance program
1 3 3
company

3.
1. Anti
Due Corruption Compliance
diligence Audit
Loss of Profits to program
2.Trainings to Employees
1 3 3
company

3. Anti Corruption Compliance


program
Loss of Profits to 1. Due diligence Audit
company & Damage 2.Trainings to Employees
3 2 6
to Company
reputation

Loss of Profits to 1. Due diligence Audit


company 2.Trainings to Employees
3 2 6
Breach of code of 3. Anti Corruption Compliance
conduct program

1. Due diligence Audit


Breach of code of 2.Trainings to Employees
1 3 3 3. Anti Corruption Compliance
conduct program

1.
3. Due diligence Audit
Anti Corruption Compliance
Breach of code of 2.Trainings
program to Employees
1 3 3
conduct

1. Due diligence Audit


Breach of code of 2.Trainings to Employees
3. Anti Corruption Compliance
1 3 3 program
conduct

1.
3. Due diligence Audit
Anti Corruption Compliance
Loss of Profits to 2.Trainings
program to Employees
1 3 3
company

1. Due diligence Audit


Breach of code of 2.Trainings to Employees
1 4 4 3. Anti Corruption Compliance
conduct
program

1. Due diligence Audit


Breach of code of 2.Trainings to Employees
3. Anti Corruption Compliance
1 5 5 program
conduct

Loss of Profits to 1.
3. Due diligence Audit
Anti Corruption Compliance
2 3 6 2.Trainings
company program to Employees

Loss of Profits to 1. Due diligence Audit


2 4 8 2.Trainings to Employees
company
3. Anti Corruption Compliance
program

3. Anti Corruption Compliance


program
0
Residual Risk Rating
Control Potential Risk
Risk Rating Probability
Impact Score
Level (1-5) Level (1-5)

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