Situation
Facing a bribery or corruption allegation?
Bribery allegations carry criminal, regulatory and reputational risk for the company as well as individuals. We investigate payments, intermediaries and books and records, and help you build anti-bribery procedures that are proportionate and defensible.
Warning signs
Signs you need an independent investigation
- Unusual payments to agents, consultants or intermediaries
- Vague invoices for “facilitation” or “liaison” services
- Gifts, hospitality or donations linked to approvals
- Allegations from employees, competitors or the media
Act quickly, act carefully
What to do in the first 48 hours
- Step 01
Preserve records
Secure payment records, contracts and communications with intermediaries.
- Step 02
Take legal advice
Bribery matters raise complex reporting and privilege questions.
- Step 03
Assess exposure across jurisdictions
Overseas laws may apply to multinational groups.
Our approach
How we investigate
- 01
Books and records review
Identify suspicious payments and their approvals.
- 02
Intermediary due diligence
Examine agents and consultants for red flags.
- 03
Communications review
Review emails and messages with eDiscovery tools.
- 04
Programme review
Benchmark policies and controls and recommend improvements.
What you receive
- Investigation findings
- Third-party risk assessment
- Anti-bribery programme recommendations
Frequently asked questions
Can a company be liable for bribery in India?
Yes. Section 9 of the Prevention of Corruption Act, 1988, introduced by the 2018 amendment, makes a commercial organisation liable if a person associated with it gives a bribe to obtain or retain business, subject to a defence of having adequate procedures in place.
Proof
Relevant case files
~₹6 Crbenefit to the manager and family quantified
The Villa on the Office Laptop
A key-account manager granted customers settlements he had no authority to give, and took a share back over many years. His own records showed where the cash went.
- Digital forensics
- Source and application of funds
- Corporate and related-party mapping
- Asset searches
~₹5 Crundue benefit quantified
The CEO's Three Vendors
A subsidiary CEO routed a rural retail rollout through vendors fronted by his own associates. The money trail led back to him.
- Procurement reconstruction
- Corporate and statutory records
- Ground intelligence
- Funds-flow tracing
Client names and identifying details are withheld to protect confidentiality. Specific references and client experiences can be shared on request, with the client’s consent.
Other situations
Facing something different?
- Received a whistleblower complaint?Investigate allegations independently, protect the whistleblower and give your board a defensible answer.
- Suspect fraud, embezzlement or financial misconduct?Establish what happened, who was involved and how much was lost, with evidence that stands up.
- Suspect vendor kickbacks or procurement fraud?Find collusion, kickbacks, inflated invoices and fictitious vendors in your purchasing and supply chain.
- Vetting a partner, vendor or acquisition target?Know who you are dealing with before you sign, invest or onboard: promoters, related parties and reputation.
- Need to trace hidden or diverted assets?Find assets that have been concealed, moved or held through others, and support their recovery.
- Facing a dispute that needs forensic evidence?Quantify losses, analyse the evidence and give expert opinion that stands up in court or arbitration.