# UK Bribery Act — Adequate Procedures ABC Program > 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. Tags: Compliance, UK Bribery Act, Anti-Bribery, Anti-Corruption, MoJ Guidance, Due Diligence ## Example Prompts - Draft an ABC programme for our UK-based consultancy operating in the Middle East and Africa - Assess bribery risks by geography and sector for our engineering firm's government contracts - Document tiered due diligence procedures for our agents and JV partners - Validate our anti-bribery programme documentation against the six MoJ principles URL: https://rakenne.app/skills/uk-bribery-act-abc-program/index.md Try this skill: https://rakenne.app/a/?skill=uk-bribery-act-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):** ```markdown ## 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. --- Back to [Skill Library](https://rakenne.app/skills/index.md)