Anti-Corruption and Anti-Bribery

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APPENDIX 5-D: Common Red Flags Indicating Heightened Potential for Corruption

Lack of written agreement or non-standard written, or needlessly complex agreement

High commissions or unusually large fees for the work or region or deal

Specific third party required or recommended by party to agreement

Lack of experience, resources or staff to support type of vendor work / engagement

Third party does not appear to be a legitimate company or has been in existence for less than one year, no independent references

Third party is a (or is related to) government official or promotes its connections to government

Insufficient due diligence (gov’t relationship, credit, experience) or lack of cooperation in due diligence

Third party appears in negative news or is subject of a government investigation or enforcement action or references illegal activities

Payments into offshore accounts or to locations not related to the deal

Use of petty cash or other poorly documented / loosely tracked slush funds (ex. marketing funds)

Inadequate, generic or otherwise questionable descriptions of activities, requests for changes to invoices or documents

Missing or incomplete documentation

Repetitive payments of same amount or round dollar amounts

Substantial activity for new vendor

Invoices paid too quickly; payments in cash or check, payments in advance

Large individual or aggregate payments/benefits to one payee

Repetitive entertainment / dinner / travel /gifts or requests for the same or requests for donations and contributions

Employees being paid who are not listed in recent company phone book or who receive no benefits, tax withholding.

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