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Building the foundations: Bribery risk assessment as the basis of effective risk mitigation

July 11, 2013 saw the launch of Transparency International UK’s latest publication, Diagnosing Bribery Risk, a practical guide to effective bribery risk assessment. Conducting a comprehensive risk assessment is the foundation for successful risk management and mitigation. Without a clear understanding of your risks, it is impossible to know if you’re covering all the bases.

The guide is aimed at businesses of all shapes and sizes and is designed to assist those charged with carrying out a bribery risk assessment to follow a relatively simple, structured process.  While the guide provides the basic theoretical framework for risk assessment, the focus is very much on how to do it in practice. The guide contains numerous case examples, signposts and practical hints to help the reader through the process. There is also a lot of practical guidance about the nature of some of the key risks for business. Importantly, the guide includes an illustrative worked example of a documented bribery brisk assessment, as well as a detailed checklist of tasks to be performed during the risk assessment process.

The guide is generic and is not specific to any size of business or industry sector. It aims to enable people in any organisation, sector or location to ask the right questions and identify and evaluate the bribery risks to which their organisation is exposed. The guide does not set out to be prescriptive — there is no one-size-fits-all solution to many of the challenges of risk assessment. Rather it seeks to establish principles by which a good risk assessment might be conducted and to provide pragmatic suggestions as to how to achieve this in practice. An example of this is the emphasis on a qualitative rather than quantitative approach to measuring and prioritising different kinds of bribery risk, focusing less on trying to attribute numerical values to the likelihood or impact of a particular bribery risk area and more on the wider implications of bribery as a risk.

The guide draws on well-established principles of risk assessment generally, but applies them specifically to bribery risk. It draws attention to aspects of the risk assessment process where traditional approaches may be particularly challenging in the context of bribery risk, which is different in nature in certain important respects from other risks affecting business.

The guide can be downloaded from


Will Kenyon was invited by Transparency International UK to be the Lead Author of “Diagnosing Bribery Risk”. He’s a partner in the Forensic Services group at PricewaterhouseCoopers LLP (“PwC”), based in London. He leads PwC’s Anti-bribery and corruption services.

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