The Group provides guidance on measures which firms may wish to adopt, including:
- Elements of an effective AB&C programme;
- Governance;
- Firm-wide policy;
- Third-Party providers;
- Principal investments & controlled fund acquisitions / joint ventures;
- Anything of value;
- Risk assessment;
- Training and awareness;
- Monitoring and testing for compliance with controls; and
- Customer-related corruption risks.
- The guidance also provides examples of corruption red flags in the document annex.
Firms should read the updated guidance document and take appropriate actions, as required.