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1

Introduction

1. 1.1

   We run our business[es] with integrity. All of us must work together to ensure our business[es] [remains OR remain] untainted by Bribery and Corruption[ and other financial crime, eg facilitation of tax evasion]. This Policy is integral to that effort and we are all bound by it.

1. 1.2

   This policy covers the use of Agents and intermediaries who help with our business. It sets out the due diligence steps required before and during the engagement of an agent or intermediary to ensure the use of such an agent or intermediary does not improperly affect our business.

1. 1.3

   This policy sits alongside and should be read in conjunction with our [insert, eg Anti-bribery and corruption policy], which can be found [insert location or link to your overarching ABC policy].

1. 1.4

   What is an agent or intermediary?

   1. 1.4.1

      Agents and intermediaries are third parties engaged to provide services for or on behalf of [insert organisation’s name] or represent our interests.

   1. 1.4.2

      They may include:

      1. (a)

         business consultants;

      1. (b)

         sales agents;

      1. (c)

         third parties retained in relation to government business or actions;

      1. (d)

         introducers;