To defend against corporate liability under the UK Bribery Act and mitigate risks under the FCPA, companies must implement an anti-corruption framework based on Six Principles of Adequate Procedures.
The Six Structural Principles
[1. Proportionate Procedures] ---> [2. Top-Level Commitment]
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[4. Due Diligence Processing] <--- [3. Regular Risk Assessment]
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[5. Communication & Training] ---> [6. Monitoring & Evaluation]

1. Proportionate Procedures
The anti-bribery controls must match the actual risks faced by the organization. A company operating in low-risk domestic retail needs simpler controls than a multinational logistics firm operating in high-risk jurisdictions.
2. Top-Level Commitment
Senior leadership must actively foster a culture where bribery is unacceptable. This commitment requires clear corporate communications, the allocation of compliance resources, and direct oversight from the board.
3. Regular Risk Assessment
The company must systematically evaluate its exposure to bribery and corruption. This analysis must be documented, updated regularly, and used to guide control enhancements.
4. Due Diligence Processing
The firm must perform background checks on all third-party agents, joint venture partners, and suppliers before onboarding them. These checks look for previous corruption links, regulatory flags, or connections to public officials.
5. Communication and Training
Anti-corruption policies must be communicated clearly throughout the organization. High-risk employees require mandatory, scenario-based training to help them spot and handle real-world bribery risks.
6. Monitoring and Evaluation
Compliance teams must test internal systems regularly to ensure controls remain effective over time. These audits help flag operational gaps, identify new risks, and incorporate industry best practices.
 
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