Risk · Compliance

Anti-Bribery & Corruption Risk Assessment for organisations that operate with integrity.

Identifying where bribery and corruption risk is concentrated in your business — and building the policies, controls, and culture needed to detect, prevent, and respond to it.

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Bribery and corruption risk is present in virtually every business that interacts with government bodies, customs authorities, licencing agencies, or procurement decision-makers. For Indian companies under the Prevention of Corruption Act, and for those with cross-border operations subject to the FCPA or UK Bribery Act, the exposure is both real and consequential.

NDS Advisors conducts structured anti-bribery and corruption risk assessments that identify where your organisation is most exposed — across geographies, business units, transaction types, and third-party relationships — and assess the adequacy of existing controls against that exposure.

Our work supports companies building or strengthening their ABC programmes, responding to regulatory enquiries, preparing for due diligence by foreign partners, or seeking to embed a culture of integrity across a growing organisation. We bring investigative, forensic, and compliance expertise to each engagement.

Our Anti-Bribery & Corruption Risk Assessment Services

ABC Risk Assessment

Structured assessment of bribery and corruption risk across the organisation — by geography, function, transaction type, and third-party relationship.

Policy & Code of Conduct Review

Review and strengthening of anti-bribery policies, codes of conduct, gift and hospitality registers, and related compliance documentation.

Third-Party Due Diligence Framework

Design of due diligence processes for agents, distributors, JV partners, and government-facing intermediaries — the highest-risk category in most ABC frameworks.

Whistleblower Programme Assessment

Review of existing whistleblower mechanisms — channel design, independence, investigation procedures, and non-retaliation protections.

ABC Training Programme

Customised anti-bribery and corruption awareness training for board, management, and front-line employees in high-risk roles.

Transaction Review

Targeted review of high-risk transactions — government contracts, regulatory approvals, customs clearances — for indicators of improper payments.

ABC Programme Design

End-to-end design of an anti-bribery compliance programme — policy, risk assessment, due diligence, monitoring, training, and investigation procedures.

Remediation Support

Advisory support in responding to identified ABC violations — including internal investigation, remediation planning, and voluntary disclosure considerations.

Our Process

1

Risk Scoping

Understanding the business model, geographies, government touchpoints, and third-party relationships to frame the risk assessment scope.

2

Risk Identification

Systematic identification of bribery and corruption risk across the business — using interviews, document review, and transaction analysis.

3

Control Assessment

Evaluation of existing ABC controls — policies, approvals, training, monitoring, and whistleblower mechanisms — against the identified risk profile.

4

Gap Analysis & Rating

Assessment of control gaps, with risk ratings for each identified exposure — providing a clear picture of where the organisation is most vulnerable.

5

Report & Remediation Plan

Detailed risk assessment report with findings, risk ratings, and a prioritised remediation plan including policy, control, and training recommendations.

Why It Matters

Identifies bribery risk before it becomes a legal exposure
Supports FCPA, UK Bribery Act, and PCA compliance
Builds a defensible compliance programme for regulators
Protects the company and its directors from personal liability
Strengthens third-party due diligence for JVs and partnerships
Builds investor confidence through demonstrated integrity controls
Reduces reputational risk from corruption allegations
Creates a culture of ethical conduct across the organisation

Frequently Asked Questions

The primary legislation is the Prevention of Corruption Act, 1988 (amended in 2018), which prohibits giving or receiving bribes involving public servants. Companies with US nexus may be subject to the FCPA, and those with UK operations to the UK Bribery Act — which has broader scope including private-sector bribery.
The majority of bribery violations involve third parties — agents, distributors, consultants — who pay bribes on behalf of the company. Companies can be held liable for third-party conduct even without direct knowledge. Third-party due diligence is therefore one of the most critical elements of any ABC programme.
An ABC risk assessment systematically identifies and evaluates the bribery and corruption risks relevant to a specific organisation — considering industry, geographies, government interaction points, and third-party relationships. It assesses the adequacy of existing controls and produces a prioritised gap analysis and remediation plan.
There is no single statutory requirement for a formal ABC programme under Indian law, though listed companies must have a vigil mechanism under the Companies Act, 2013. However, having a documented programme is increasingly expected by foreign investors, JV partners, and international clients — and provides a legal defence in the event of a violation.
An effective programme should include a confidential reporting channel, clear non-retaliation protections, an independent investigation process, defined resolution timelines, and regular communication to employees. We assess and design programmes meeting both Indian law requirements and international best practice.
If our assessment identifies specific indicators of corruption, we advise on next steps — which may include a targeted forensic investigation. We work with the company and its legal advisors on appropriate response measures, including internal discipline, contract remediation, and voluntary disclosure considerations.

Build integrity into your business before regulators do.

Talk to our team about an anti-bribery risk assessment and compliance programme design for your organisation.