Documenting decisions

In anti-bribery work, the record is half the protection. Two people can make the same decision, but the one who documented the reasoning is in a far stronger position when the decision is questioned two years later.

Why records matter

Bribery investigations happen long after the events, when memories have faded and people have moved on. What survives is the paper trail: emails, register entries, approval records, meeting notes, due diligence files. If a decision was made properly, the record proves it. If there is no record, investigators, auditors, and prosecutors are left to assume the worst, and the adequate procedures defence weakens with every gap.

What to document

Get into the habit of recording the moments where judgement was exercised:

• Gifts and hospitality given, received, and declined, in the register, at the time
• Approvals sought and given, including who approved and on what basis
• Due diligence on third parties, including the questions asked and the answers received
• The justification for engaging an intermediary and how their fee was set
• Conflicts of interest declared, and how they were managed
• Red flags spotted, who they were escalated to, and how they were resolved

The standard to aim for is that a stranger reading the file later could understand what was decided, by whom, and why, without asking you anything.

Honest records only

Documentation cuts both ways. Records must be accurate and complete. Mislabelling a payment, backdating an approval, splitting an invoice to stay under a threshold, or writing a file note designed to obscure rather than explain is not protection, it is evidence of wrongdoing. Accurate books and records are also a legal requirement in their own right, and false accounting is a separate criminal offence.

If you would hesitate to write down the real reason for a decision, that hesitation is telling you the decision is wrong, not that the record should be vague.