Recording and reporting corruption

If you know or suspect that an activity involves a corruption offence, then you should consider the following recording and reporting implications:

Recording corruption offences:

You should, as soon as possible, make a record of the incident, noting all relevant facts.  Such records will provide valuable evidence of the incident which may be used in a prosecution.  They may also help to protect you should allegations be made against you.

Voluntary reporting:

You may be under a duty to report a corruption offence (see next paragraph).  If you are not, you should nevertheless report the incident, where appropriate, to your manager or your organisation’s compliance function, and to your professional institution (where the matter involves a fellow professional).  You should also consider reporting to the authorities.   However, do not make any such report if you fear for your safety or for the safety of another if you make such report.

Duty to report:

You may be under a duty to report a corruption offence.  This duty can be imposed by any one or more of:

  • Your employer, who may impose a duty to report under your employment contract or a corporate code of conduct
  • Your professional institution, who may impose a duty to report under your membership conditions or a professional code of conduct
  • Your country of residence or the country where the offence took place, which may impose a duty to report under law.

Failing to report:

If there is a duty to report, and you fail to report, you could be exposed to disciplinary proceedings by your employer or professional institution, or to prosecution.

Therefore, make yourself aware of, and comply with, any duty to report (unless you fear that complying with such duty could lead to physical harm to you or another).

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1st April 2024