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ACCA Applied Skills · Corporate and Business Law (Global) · Fraudulent and criminal behaviour

Which of the following would most clearly help a company show it had 'adequate procedures' to prevent bribery?

A written anti-bribery policy supported by training, due diligence on agents and a whistleblowing channel best evidences adequate procedures. Verbal assurances are insufficient, and disguising bribes as fees is concealment that makes matters worse.

  1. AA written anti-bribery policy backed by training, due diligence on agents and a whistleblowing channelCorrect
  2. BVerbal assurances from agents that they will obey the law
  3. CA rule that bribes must be recorded as consultancy fees

Explanation

Adequate procedures typically include top-level commitment, risk assessment, due diligence, policies, training, monitoring and reporting channels. Verbal assurances alone are weak. Disguising bribes as consultancy fees is itself false accounting and concealment, so it cannot be a defence.

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