Chartered Accountants in India, working with clients across the UK

Anti-Bribery Risk Assessment
Risk Advisory · Anti-bribery

Anti-bribery risk assessmentfor your Indian operations.

Both the UK Bribery Act 2010 and India's Prevention of Corruption Act hold companies liable for bribes paid on their behalf, unless they had adequate procedures to prevent them. We assess where bribery risk sits in your Indian operations, test your controls and help you build procedures that stand up.

UK and Indian law coveredFees agreed in writingPractical, risk-based
PurposeFind and reduce bribery risk
UK lawBribery Act, section 7
Indian lawCorporate offence since 2018
DefenceAdequate procedures

The law in both countries.

 UK Bribery Act 2010Prevention of Corruption Act (India)
Corporate offenceFailure to prevent bribery by associated personsCommercial organisation liable for bribes to public servants by associated persons
ReachUK companies and businesses with a UK presence, wherever the bribe is paidOrganisations in India, and foreign organisations doing business in India
DefenceAdequate procedures to prevent briberyAdequate procedures in line with government guidelines
Private sector briberyCoveredMainly public servants

Where bribery risk usually sits in India.

Licences

Permits and approvals

Factory licences, environmental clearances and local permissions.

Customs

Imports and exports

Clearance, classification and inspections.

Third parties

Agents and consultants

Intermediaries paid success fees or vague retainers.

Sales

Government customers

Public tenders and state-owned customers.

Hospitality

Gifts and entertainment

Festive gifts and hospitality to officials.

Payments

Cash and petty expenses

Cash payments and poorly supported expenses.

Our assessment.

01
Map

Identify risk areas

Interviews and a review of how the business interacts with officials and third parties.

02
Review

Third parties

Due diligence on agents, consultants and distributors. See Corporate Intelligence.

03
Test

Payments and expenses

Data analysis of payments, gifts and petty cash.

04
Assess

Controls

Policies, approvals, contracts and training, in practice.

05
Report

Risks and actions

A risk rating and a practical action plan for the UK board.

Why clients choose us for audits.

Chartered Accountants

Every audit is led and signed by Chartered Accountants in India.

Reports for UK readers

Findings written for UK boards, audit committees and group auditors.

Scope in writing

A written engagement letter with scope, timetable and fee.

Independent and careful

Independence checks and a second-partner review on every report.

Secure and online

Encrypted document sharing, with site visits where the work needs them.

Practical findings

Clear, prioritised recommendations your team can act on.

Anti-bribery assessments for UK companies in India.

We carry out audits in India for UK groups, investors and lenders headquartered anywhere in the UK, reporting in a form their UK boards and auditors can use.

London

City of LondonCanary WharfHarrowWembleySouthallHounslowIlfordEast HamCroydonEdgware

South East

ReadingSloughMilton KeynesOxfordWatfordLutonCrawleyGuildford

Midlands

BirminghamLeicesterCoventryNottinghamWolverhamptonDerbyNorthampton

North of England

ManchesterLeedsBradfordSheffieldLiverpoolNewcastlePreston

East and South West

CambridgePeterboroughBristolSwindonSouthamptonBath

Scotland, Wales, NI

EdinburghGlasgowAberdeenDundeeCardiffSwanseaBelfast

Anti-bribery risk assessment FAQs.

It can. A UK company can be liable for failing to prevent bribery by associated persons, which can include subsidiaries, employees and agents acting for it in India.
Yes. Since 2018, the Prevention of Corruption Act makes commercial organisations liable for bribes given to public servants by associated persons, with a defence of adequate procedures.
Risk-based policies, due diligence, controls, training and monitoring that are proportionate to the bribery risks the business faces.
Usually every year or two, or when the business enters new markets or starts working with new government customers or agents.

Confident your Indian operations are bribery-free?

We will assess the risks and controls, and build procedures that stand up.

This page is general guidance based on the Companies Act, 2013, Indian tax law and regulator guidelines as they stand. It is not legal or financial advice for your situation. Thresholds and requirements can change, so please speak to us before acting on it.