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* * * * * * * * * * * * * * * * * * Proportionality: The action you take should be proportionate to the risks you face and to the size of your business. So you might need to do more to prevent bribery if your organisation is large, or if you are operating in an overseas market where bribery is known to be commonplace, compared to what you might do if your organisation is small, or is operating in markets where bribery is not prevalent. Top Level Commitment: Those at the top of an organisation are in the best position to ensure their organisation conducts business without bribery. If you are running a business, you will want to show that you have been active in making sure that your staff (including any middle management) and the key people who do business with you and for you understand that you do not tolerate bribery. You may also want to get personally involved in taking the necessary proportionate action to address any bribery risks. Risk Assessment: Think about the bribery risks you might face. For example, do some research into the markets you operate in and the people you deal with, especially if you are entering into new business arrangements and new market overseas (see “how do I assess risk”, below). Due Diligence: Knowing exactly who you are dealing with can help to protect your organisation from taking on people who might be less than trustworthy. You may therefore want to ask a few questions and do a few checks before engaging others to present you in business dealings. Communication: Communicating your policies and procedures to staff and to others who will perform services for you enhances awareness and helps to deter bribery by making clear the basis on which your organisation does business. You may want to think about whether additional training or awareness raising would be appropriate or proportionate to the size and type of your business. Monitoring and Review: The risks you face and the effectiveness of your procedures may change over time