Anti-Corruption and Anti-Bribery

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APPENDIX 5-C: Checklist for Managing Third-Party Risk

Third parties are under formal contractual agreement with company, and management has contract on file.

Regular audits are conducted by company to ensure third-party contractual agreements are managed and enforced as agreed.

Contractual agreements with third parties clearly set forth expectations regarding the relationship and adherence to specific company standards and policies.

Third-party contracts prohibit third parties from unilaterally subcontracting its contractual responsibilities with other entities.

Nature of relationship clearly identifies legal status of entity, place of incorporation.

Third party conducts background checks on all employees, contractors, associates, and others working on its behalf.

Company has a code of conduct in place applicable to third parties or requirement that third parties have own code. Company addresses how the code is formally applied and enforced with third parties.

Third parties certify that they have read and understood the company’s code of conduct or their own substantially similar code.

Third parties receive periodic, effective training and communications (in local language) on standards, culture, compliance, and other legal requirements.

Company has a widely publicized and readily available global reporting mechanism and process where employees, contractors, third parties, agents, etc. can seek guidance, report concerns, and ask questions (anonymously, if desired).

Anti-bribery/anti-corruption standards and training are effectively communicated and provided to everyone in the organization to include employees, third parties, contractors, etc.

Third parties are required to certify that they have received, completed, understand, and will comply with anti-corruption/anti-bribery policy and training.

Third party is NOT a current or former government official, employee or agent, or a relative.

Clearly defined and legitimate business purpose exists for engaging third parties.

Third party is qualified and experienced to engage in the service or activity they were retained to undertake.

Third parties paid via standard payment protocols established by company (e.g., direct deposit).

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