Anti Bribery And Corruption Risk Assessment Template for United Arab Emirates

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Key Requirements PROMPT example:

Anti Bribery And Corruption Risk Assessment Template

"I need an Anti Bribery And Corruption Risk Assessment Template for our UAE-based construction company that handles government contracts, with particular focus on procurement processes and third-party relationships with suppliers across the Middle East region, to be implemented by March 2025."

Document background
The Anti Bribery And Corruption Risk Assessment Template has been developed to help organizations in the UAE systematically evaluate their exposure to corruption risks and ensure compliance with local and international anti-corruption laws. This document becomes necessary when organizations need to conduct regular risk assessments, enter new markets, evaluate third-party relationships, or respond to regulatory requirements. The template aligns with UAE Federal Law No. 3 of 1987 (UAE Penal Code), UAE Federal Decree-Law No. 11 of 2008, and other relevant UAE legislation, while also considering international standards such as the United Nations Convention Against Corruption. It provides a structured approach to identifying risk areas, assessing control effectiveness, and developing mitigation strategies specific to the UAE business environment.
Suggested Sections

1. Executive Summary: High-level overview of the risk assessment findings, key risks identified, and major recommendations

2. Introduction and Scope: Purpose of the assessment, scope of activities covered, and methodology used

3. Regulatory Framework: Overview of applicable UAE laws, international conventions, and other relevant regulations

4. Organization Overview: Description of business operations, corporate structure, and key stakeholders

5. Risk Assessment Methodology: Detailed explanation of risk assessment approach, scoring criteria, and evaluation methods

6. Business Operations Analysis: Analysis of different business units, operations, and third-party relationships

7. Geographic Risk Analysis: Assessment of risks associated with different geographic locations where the organization operates

8. Key Risk Areas: Identification and analysis of primary corruption risk areas including public interactions, third parties, gifts and hospitality

9. Current Controls Assessment: Evaluation of existing anti-corruption controls and their effectiveness

10. Gap Analysis: Identification of gaps between current controls and required controls

11. Risk Mitigation Recommendations: Specific recommendations for addressing identified risks and closing control gaps

12. Implementation Plan: Proposed timeline and steps for implementing recommended controls and improvements

Optional Sections

1. Industry-Specific Risk Analysis: Detailed analysis of corruption risks specific to the organization's industry - recommended for companies in high-risk sectors

2. Government Interaction Assessment: Detailed assessment of interactions with government officials - necessary for organizations with significant public sector engagement

3. Merger and Acquisition Risks: Assessment of corruption risks in M&A activities - required for organizations involved in M&A transactions

4. Supply Chain Risk Analysis: Detailed assessment of corruption risks in the supply chain - recommended for organizations with complex supply chains

5. Joint Venture Risk Assessment: Analysis of corruption risks related to joint ventures - necessary for organizations with JV operations

6. Human Resources Risk Assessment: Analysis of HR-related corruption risks - recommended for large organizations with complex HR structures

Suggested Schedules

1. Appendix A: Risk Assessment Matrix: Detailed risk scoring matrix with likelihood and impact criteria

2. Appendix B: Control Testing Results: Detailed results of testing performed on existing controls

3. Appendix C: Interview Log: List of stakeholder interviews conducted and key findings

4. Appendix D: Document Review List: List of policies, procedures, and other documents reviewed

5. Appendix E: Risk Register: Detailed register of all identified risks with ratings and mitigation measures

6. Appendix F: Action Plan Template: Template for documenting and tracking implementation of recommendations

7. Appendix G: Red Flags Checklist: Checklist of corruption red flags specific to different business activities

8. Appendix H: Compliance Questionnaire: Standard questionnaire used for gathering information during the assessment

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions
Clauses
Relevant Industries

Financial Services

Construction and Real Estate

Oil and Gas

Healthcare

Defense and Security

Government Services

Transportation and Logistics

Manufacturing

Telecommunications

Retail and Distribution

Hospitality and Tourism

Education

Professional Services

Energy and Utilities

Mining and Natural Resources

Relevant Teams

Legal

Compliance

Internal Audit

Risk Management

Corporate Governance

Ethics

Regulatory Affairs

Operations

Finance

Human Resources

Procurement

Business Development

Corporate Affairs

Executive Leadership

Board Secretariat

Relevant Roles

Chief Compliance Officer

Risk Management Director

Legal Counsel

Internal Audit Manager

Ethics Officer

Compliance Manager

Risk Assessment Specialist

Corporate Governance Director

Chief Legal Officer

Head of Internal Control

Regulatory Affairs Director

Anti-Money Laundering Officer

Due Diligence Manager

Chief Risk Officer

Corporate Secretary

Head of Business Development

Operations Director

Finance Director

Industries
UAE Federal Law No. 3 of 1987 (UAE Penal Code): The primary legislation that criminalizes bribery and corruption in the UAE, particularly Articles 234-239 which deal with public sector bribery and Articles 236-237 which address private sector bribery
UAE Federal Decree-Law No. 11 of 2008: Law regarding Human Resources in the Federal Government, which includes provisions on conflict of interest and abuse of public office
UAE Federal Law No. 4 of 2002: Law regarding Criminalization of Money Laundering, which is relevant as corruption often involves money laundering activities
United Nations Convention Against Corruption (UNCAC): International anti-corruption convention ratified by the UAE in 2006, providing framework for preventing and combating corruption
UAE Federal Law No. 19 of 2016: Anti-Commercial Fraud Law that includes provisions related to business integrity and prevention of fraudulent practices
Dubai Law No. 4 of 2016: Dubai Financial Fraud Law, specifically relevant for companies operating in Dubai, addressing financial fraud and corruption
UAE Federal Law No. 19 of 2018: Foreign Direct Investment Law that includes provisions on business transparency and anti-corruption measures
US Foreign Corrupt Practices Act (FCPA): While not UAE legislation, it has extraterritorial reach and is crucial for UAE companies doing business with US entities or using US financial system
UK Bribery Act 2010: Similar to FCPA, has extraterritorial reach and is relevant for UAE companies doing business with UK entities or having UK operations
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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