1

Introduction

1. 1.1

   We run our business[es] with integrity. All of us must work together to ensure our business[es] [remains OR remain] untainted by financial crime, including Bribery, Corruption, facilitation of tax evasion, fraud, etc. This Policy is integral to that effort and we are all bound by it.

   This policy covers the use of Agents, intermediaries, and other associated persons who provide services for [insert organisation’s name] or on our behalf. It sets out the due diligence steps required before and during the engagement of an agent, etc to ensure their use does not improperly affect our business.

1. 1.2

   This policy sits alongside and should be read in conjunction with our related financial crime prevention policies, eg our:

   1. 1.2.1

      Anti-bribery and corruption policy;

   1. 1.2.2

      Tax evasion facilitation prevention policy;

   1. 1.2.3

      Fraud risk management policy[; OR .]

   1. 1.2.4

      [[insert other.]]

1. 1.3

   What is an agent, intermediary or associated person?

   1. 1.3.1

      The question as to whether a person is performing services for or on behalf of an organisation is to be determined by reference to all the relevant circumstances