UK Bribery Act — Adequate Procedures ABC Program

Overview

Draft and validate the Anti-Bribery & Corruption (ABC) programme documentation required for the ‘adequate procedures’ defence under UK Bribery Act 2010 §7. Structures the programme around the Ministry of Justice’s six principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication/training, and monitoring/review.

Example Conversation

You: We’re a UK engineering firm with contracts in the Middle East and Africa. We need ABC programme documentation for the adequate procedures defence. Can you draft and validate?

Agent: I’ll draft the ABC programme structured around the six MoJ principles: proportionate procedures for your risk profile, board-level commitment statement, bribery risk assessment by geography and sector, tiered due diligence for agents and JV partners, a training and communication plan, and monitoring/review with a whistleblowing channel. Then I’ll run adequate_procedures_checker.

Agent: Created abc-programme-draft.md. Running adequate_procedures_checker…

Agent: Check FAIL — the due diligence section mentions DD procedures but lacks risk-based tiers (e.g. standard vs. enhanced DD). Also, no review cadence is specified in the monitoring section. I’ll add tiered DD (standard for low-risk, enhanced for high-risk jurisdictions) and an annual review cycle.

Agent: Updated and re-ran adequate_procedures_checker: PASS — all six MoJ principles addressed, geographic and sectoral risk factors present, risk-based DD tiers defined, whistleblowing channel described, and annual review cadence specified.

What the Tools Validate

The skill includes one extension tool:

adequate_procedures_checker validates ABC programme documentation across five checks:

• MoJ six principles coverage — All six principles must be addressed: proportionate procedures, top-level commitment, risk assessment, due diligence, communication/training, and monitoring/review. Reports which are missing.
• Geographic and sectoral risk factors — The risk assessment must include geographic risk factors (e.g. country risk, CPI ranking, high-risk jurisdictions) and sectoral risk factors (e.g. industry-specific vulnerabilities).
• Risk-based DD tiers — The due diligence section must include risk-based tiers or categories (e.g. standard/enhanced, low/medium/high risk).
• Whistleblowing mechanism — A confidential reporting channel, hotline, or speak-up procedure must be described.
• Monitoring/review cadence — A defined review frequency must be specified (e.g. annual, quarterly).

Output: Per-check PASS/FAIL with an overall result. For each failing check, the report identifies what is missing or incomplete. Run on the programme draft; fix gaps and re-run until the overall check passes.

Output Excerpt

Excerpt from a generated ABC programme and sample checker report.

ABC programme (excerpt):

## 1. Proportionate Procedures

The ABC programme is proportionate to the nature, scale, and complexity of the organisation's activities and the bribery risks it faces. The risk-based approach prioritises resources on high-risk areas.

## 3. Risk Assessment

### Geographic risk
Operations in jurisdictions with CPI scores below 40 (Transparency International) are classified as high-risk. Current high-risk countries: [list]. All engagements in high-risk jurisdictions require enhanced due diligence.

### Sectoral risk
Government contracting and infrastructure projects are classified as elevated sector risk due to public official interaction and subcontracting chains.

## 4. Due Diligence

| DD Tier | Criteria | Scope |
|---------|----------|-------|
| Standard | Low-risk jurisdiction, established counterparty | Basic screening, sanctions check |
| Enhanced (EDD) | High-risk jurisdiction, government-linked, or agent | Full background check, site visit, ongoing monitoring |

## 6. Monitoring & Review

Annual review of the ABC programme by the Compliance Committee. Internal audit of high-risk engagements every 12 months. Whistleblowing hotline: [details]. Speak-up reports are investigated within 30 days.

adequate_procedures_checker report (excerpt):

=== MoJ Six Principles Coverage ===
Result: PASS
All six MoJ principles are addressed.
Covered (6/6): 1 (Proportionate Procedures), 2 (Top-Level Commitment), 3 (Risk Assessment), 4 (Due Diligence), 5 (Communication & Training), 6 (Monitoring & Review)

=== Risk Assessment — Geographic & Sectoral Factors ===
Result: PASS
Risk assessment includes both geographic and sectoral risk factors.

=== Due Diligence — Risk-Based Tiers ===
Result: PASS
Due diligence section includes risk-based tiers or categories.

=== Whistleblowing / Reporting Mechanism ===
Result: PASS
Whistleblowing or confidential reporting mechanism is described.

=== Monitoring & Review Cadence ===
Result: PASS
Monitoring and review section includes a defined review cadence.

OVERALL: PASS — All adequate procedures checks passed.

Getting Started

Add your source materials to the project workspace (existing ABC policies, risk registers, DD procedures), then activate the UK Bribery Act — Adequate Procedures ABC Program skill. The agent will guide you through risk assessment, policy drafting, DD procedures, training plan, monitoring, and running adequate_procedures_checker to validate the programme against MoJ guidance.