This article unpacks the Attorney-General's Department's adequate procedures guidance ahead of Australia's failure-to-prevent foreign bribery offence. It sets out the principles of proportionality and effectiveness underpinning strong anti-bribery compliance systems, and walks through the key features companies need — risk assessment, due diligence, training, whistleblowing channels, and monitoring — to build a defensible compliance program.

Allens breaks down the Attorney-General's draft guidance on "adequate procedures" — the defence available to companies facing the failure to prevent foreign bribery offence. The piece outlines the core principles of proportionality and effectiveness, and the key features regulators expect to see in a compliance program, including risk assessment, due diligence, training, whistleblowing mechanisms, and senior management engagement.

This webinar highlights the important role internal auditors can provide as a critical line of defence against bribery and corruption. Topics include Key factors and environments that facilitate corruption and misconduct risks; Preventing corruption: risk assessments, policies & procedures; Detecting corruption: monitoring systems, controls and reporting mechanisms; and Addressing corruption: investigations and responses

This publication supports Australian businesses to strengthen anti-bribery risk and compliance management and align anti-bribery procedures with international best practice. Access practical guidance on building and implementing adequate procedures across six key areas: management dedication, risk assessment, due diligence, confidential reporting and investigation, communication and training, and monitoring and review. Learn how to implement adequate procedures across compliance areas.

This factsheet is designed to support small to medium sized enterprises to meet existing compliance obligations and establish a best practice anti-bribery system. Read about the key considerations and practical steps involved in implementing adequate procedures to prevent bribery.

Putting in place an anti-bribery policy is an important part of establishing and maintaining adequate procedures to prevent bribery and corruption. Use this template as a starting point when creating a tailored anti-bribery policy for your business. Adapt this template to your business's specific operating risks, including the activities and geographies that present the highest risk of bribery and corruption issues.