Version 2.0 · Updated 10 November 2026

Download the printable planner (PDF, Version 2.0)

A third party can have a valid registration, a signed policy and a completed questionnaire while the proposed work or payment still needs explaining. Use this planner to turn those explanations into a record: what you know, what remains unresolved, what needs to happen next, and who has authority to decide.

It is a working tool for compliance practitioners, procurement and finance teams assessing bribery and corruption exposure before appointment, renewal or a material change. The completed output is an evidence record, an action plan and an authorised decision with any conditions and ongoing checks. Use one record per engagement; the same supplier may present different exposure in different roles.

Start with the next commitment

Identify what is about to happen: signature, work starting, representation before a public body, a subcontractor appointment or payment. Record the date and who controls that activity. This is the point the planner calls a gate. A check completed before payment may already be too late if the exposure begins when someone starts acting on your behalf.

On the first page, describe the business need, deliverables, value and currency, locations and proposed flow of money. Name the sponsor, relationship owner, preparer and authorised decision maker. Record the applicable policy and authority limits, relevant jurisdictions, and any conflict requiring recusal. The sponsor explains the need; the designated reviewer challenges the evidence; the authorised approver makes the decision. Internal audit can independently assess the process within its remit rather than take responsibility for management’s engagement decisions.

This is a bribery and corruption planner. Link sanctions, export controls, regulated customer due diligence, privacy, human rights and other specialist work to their responsible processes. Record who owns each referral, its current status and which gate depends on its result. A referral is still open until the receiving owner acknowledges it and its remaining work is tracked.

Record what the evidence supports

Work through the twelve prompts in the PDF. They cover purpose and capability; ownership and connections; public contacts, locations, delegates and benefits; fees and recipients; adverse information; and the controls needed to verify work and notice changes. Scale enquiries to the actual exposure and the information you may lawfully obtain. For each prompt, record a factual answer, evidence reference and date, then select one status:

  • Supported: evidence supports the specific answer recorded. It does not mean the relationship is low risk.
  • Concern: an adverse indication, contradiction or unexplained departure needs attention. It is not a finding of misconduct.
  • Unknown: information is missing or insufficient. Treat a blank answer as Unknown.
  • Not applicable: explain why the question does not apply. Unavailable records are an information gap.

Keep evidence status separate from exposure. A verified commission linked to a public award can still need enhanced review. Conversely, a news report about a similarly named company needs identity resolution before its contents are attributed to your proposed partner. Record allegations as allegations and check the underlying record and current procedural status where material.

Choose the next action, not a score

The routing below is an editorial design for this worksheet. Adapt it to your organisation’s law, policies and decision authority. Apply every relevant route; completing more low-exposure checks does not cancel a material unresolved issue.

  • Pause at the affected gate and escalate where there is a credible indication of an improper benefit or fabricated evidence, an unresolved material ownership or recipient mismatch, an unverified beneficiary change, a possible applicable prohibition, or pressure to bypass a mandatory control. For an existing engagement, promptly ask the authorised operational, legal or finance team to decide and implement the appropriate hold. Record confirmation; sending the request does not implement it. Preserve records and use authorised reporting or investigation channels without informal accusations.
  • Arrange enhanced review for official-facing intermediaries, material conflicts, award-linked fees, opaque ownership, consequential delegation, unusual payment arrangements or credible adverse information. Ask a precise question and assign someone able to check it independently. These exposures may remain significant even when fully documented.
  • Resolve gaps by naming the missing fact, verification method, owner, deadline and affected gate. A material gap keeps that gate pending. If it also meets a pause trigger, follow that route.
  • Submit for normal review when the required evidence and specialist results are available for the next gate and no unresolved higher route applies. The worksheet itself grants no permission.

Make conditions operational

Use one action record per issue. State the fact, allegation or gap; its evidence; the next check or safeguard; its owner and deadline; and the activity it affects. For a safeguard, specify what it should achieve, who operates it, what record proves it ran, who checks the result and what happens if it fails. A contract clause alone does not demonstrate that a control operates.

The approver records proceed, proceed with conditions, defer, decline or refer, with reasons, authority and date. Each condition needs an owner, a deadline before the exposure arises, evidence of completion and an operational block if unmet. Record the person who confirms release of that block. Any policy exception needs its own permitted basis, rationale, authorised approver, limits and expiry. It cannot override a legal prohibition or turn missing evidence into verified fact.

Keep the decision open to new evidence

Assign a monitoring owner and a review date suited to the exposure. Decide what will be examined: for example, meeting records, accepted deliverables, invoices or approved delegates. Record the result and response to failures. Reopen the assessment on material changes to ownership, activities, official contacts, delegates, fees or bank details, and on new credible concerns or breached conditions.

A file is ready for a decision only when the next gate, evidence limits, unresolved issues and responsible people are visible. Before acting on the decision, verify its required conditions or record any separately authorised, permitted policy waiver. Tell the person controlling the activity exactly what is authorised. Continue tracking open actions after that point.

Using the PDF

Print and write, or copy the fields into an approved internal record. The PDF is a static worksheet: it does not calculate a result, save entries automatically or transmit answers. Use references to sensitive records held in approved systems. Copy action pages when needed and label continuation sheets with the case reference, question or action ID, preparer, date and page number. The fictional examples show a routine review, a concerning payment request and an incomplete file with a limited policy exception.

Basis and limits

The planner adapts international good practice rather than prescribing a universal legal procedure. OECD’s 2021 Anti-Bribery Recommendation, Annex II A.6 addresses documented diligence and continuing oversight of business partners in the foreign-bribery context. UNODC and UN Global Compact’s 2026 practical guide, chapter III.I covers applying an anti-corruption programme to business partners. UK Ministry of Justice guidance, Principle 4 provides UK-context examples of proportionate enquiries. US DOJ’s September 2024 evaluation guidance, section I.E examines third-party rationale, fees, services and lifecycle management from a US prosecutorial perspective. The fields, statuses and routing rules are editorial design choices, not quotations from those sources.

Prepared with Metis (AI).

Version history: Version 2.0 restructures the planner around evidence, decision gates, conditions and monitoring. Version 1.1 (8 November 2026) and Version 1.0 (5 November 2026) are retained as earlier editions.