Annual anti-bribery self-audit checklist

Answer each question Yes, No or Partly, and note the evidence. Every "No" or "Partly" gets an owner and a date. Keep the completed checklist: it is evidence that you take the policy seriously.

Completed by: ____________ Date: ________ Reported to the directors on: ________

A. Leadership and policy

#	Question	Y / N / Partly	Evidence and action
1	Is there a written anti-bribery policy approved by the directors in the last 12 months?
2	Does it say plainly that hidden commissions and kickbacks are forbidden, in both directions?
3	Is a named person responsible for it, with time and authority to do the job?
4	Have the directors said, in writing and in person, that they will support staff who lose business by following it?
5	Does the policy reflect each country where we operate (the supplements)?

B. Risk

#	Question	Y / N / Partly	Evidence and action
6	Has a risk assessment been done in the last 12 months?
7	Does it cover wine and provisions, fuel and port services, yard and refit work, tenders and equipment, agents and intermediaries, and shows and sponsorship, as relevant to us?
8	Have all actions from the last assessment been done?

C. People and training

#	Question	Y / N / Partly	Evidence and action
9	Has everyone read the policy and signed the annual certificate?
10	Has everyone in sales, purchasing, finance and management been trained in the last 12 months?
11	Did the training include real yachting examples and test understanding?
12	Can a randomly chosen member of the sales team explain, in their own words, what to say when asked for a commission?
13	Do new joiners receive the policy and training in their first month?

D. Gifts, hospitality and samples

#	Question	Y / N / Partly	Evidence and action
14	Is there a register, and has it been used?
15	Does it record declined offers as well as accepted ones?
16	Were all items above the limit approved in advance?
17	Has the register been reviewed by someone senior in the last 6 months?
18	Has any gift, sample or hospitality been linked to a pending order or decision?

E. Requests for commission

#	Question	Y / N / Partly	Evidence and action
19	Are requests for commission logged?
20	Have we looked at the pattern: who asks, how often, how?
21	Has anyone asked us for something and been told "yes" by someone in the company?
22	Have repeated requests been escalated?

F. Intermediaries

#	Question	Y / N / Partly	Evidence and action
23	Do we have a list of every agent, broker, introducer and distributor?
24	Has each one been through due diligence in the last 12 months?
25	Does each have a written contract with anti-bribery clauses?
26	Is each paid only to an account in its own name, in the right country, against invoices?
27	Are the fees reasonable and in line with the services?

G. Money and records

#	Question	Y / N / Partly	Evidence and action
28	Is every payment traceable and correctly described?
29	Have we checked for split invoices, unusual credit notes, discounts that do not appear on invoices, and payments to individuals?
30	Is cash restricted by a written limit?
31	Are sales commission and bonus plans free of any link to benefits for customers' staff?
32	Are records kept for the period in the country supplement?

H. Speaking up

#	Question	Y / N / Partly	Evidence and action
33	Does everyone know how to raise a concern, and that they will be protected?
34	Has any concern been raised in the last 12 months? (None is not necessarily good news.)
35	Were all concerns acknowledged, investigated and closed in writing?
36	Do we comply with local whistleblower rules where they apply to us?

I. Monitoring and learning

#	Question	Y / N / Partly	Evidence and action
37	Have we tested a sample of transactions against the policy?
38	Have we reviewed incidents and near-misses and changed anything as a result?
39	Do we know what our competitors, customers and suppliers say about our stance?
40	Would we be comfortable showing this checklist and our register to an owner, a regulator or a journalist?

Result

Number of Yes / Partly / No: ____ / ____ / ____

Three most important actions: 1. ____________ 2. ____________ 3. ____________

Signed (policy owner): ____________ Seen by a director: ____________

General information, not legal advice.