FCG 6.3 Further guidance

1FCTR contains the following additional material on bribery and corruption:

1. • FCTR 9 summarises the findings of the FSA’s thematic review Anti-bribery and corruption in commercial insurance broking and includes guidance on:

   1. ◦ Governance and management information (FCTR 9.3.1G)

   2. ◦ Risk assessment and responses to significant bribery and corruption events (FCTR 9.3.2G)

   3. ◦ Due diligence on third-party relationships (FCTR 9.3.3G)

   4. ◦ Payment controls (FCTR 9.3.4G)

   5. ◦ Staff recruitment and vetting (FCTR 9.3.5G)

   6. ◦ Training and awareness (FCTR 9.3.6G)

   7. ◦ Risk arising from remuneration structures (FCTR 9.3.7G)

   8. ◦ Incident reporting (FCTR 9.3.8G)

   9. ◦ The role of compliance and internal audit (FCTR 9.3.9G)

2. • FCTR 13 summarises the findings of the FSA’s thematic review on Anti-bribery and corruption systems and controls in investment banks and includes guidance on:

   1. ◦ Governance and management information (FCTR 13.3.2G)

   2. ◦ Assessing bribery and corruption risk (FCTR 13.3.3G)

   3. ◦ Policies and procedures (FCTR 13.3.4G)

   4. ◦ Third party relationships and due diligence (FCTR 13.3.5G)

   5. ◦ Payment controls (FCTR 13.3.6G)

   6. ◦ Gifts and hospitality (FCTR 13.3.7G)

   7. ◦ Staff recruitment and vetting (FCTR 13.3.8G)

   8. ◦ Training and awareness (FCTR 13.3.9G)

   9. ◦ Remuneration structures (FCTR 13.3.10G)

   10. ◦ Incident reporting and management (FCTR 13.3.11G)