We are committed to ensuring that those who provide goods and services to us, and act on our behalf, do so with integrity. In 2014, we formalised our supply chain anti-corruption due diligence procedure. This follows the risk-based process set out in the diagram.
As part of this formal process, we designed: due diligence questionnaires that are issued to suppliers during the selection process; a guidance document to help assess questionnaire responses; templates for generating due diligence reports; and a central repository of due diligence reports to avoid duplication of work where one company was tendering for several contracts.
We also implemented a training and communication strategy to ensure that this process is embedded in the business. In 2014, we delivered workshops to about 200 staff involved in conducting due diligence evaluations or to budget/contract holders who needed to understand the various risk categories.
Our due diligence questionnaires are designed to evaluate whether the supplier has an adequate compliance programme in place. This serves as a reminder to our prospective suppliers of the measures we expect to see, as well as emphasising the requirements set out in the anti-corruption clause of our contracts. In cases where prospective suppliers could not demonstrate they had an adequate compliance programme, we held meetings with them to discuss the changes that we expected them to make within an agreed timeframe. The process had a positive impact on suppliers who used the opportunity to improve their compliance programme and resources where necessary.