What is the third-party anti-bribery due diligence form template?
Many corruption cases involve a third party: a sales agent paid a large commission, a customs broker who "speeds things up", a consultant with a relative in the ministry. That's why compliance teams ask intermediaries to answer a standard set of questions before they're engaged and at renewal.
This template covers the usual ground in seven short pages. The company's identity and contact. Who really owns and runs it, including people behind holding companies. What the engagement involves, where, and how they'll be paid, with a pointed question about payments to accounts in another country or name. Its compliance program: a written policy, training, rules on gifts and facilitation payments, an audit and a speak-up channel. Investigations, sanctions or debarment, and two business references.
The central question asks whether any owner, director, employee or close relative is a current or former government official, party official, candidate or state-company employee. A yes reveals a disclosure section: who, their role, the position and dates, whether they could influence decisions, and how they're kept apart from the work. Each signed questionnaire is filed as a PDF in your FileIt vault.
- Best for
- Compliance, legal and procurement teams engaging intermediaries
- Filled in by
- An authorized representative of the third party
- Time to complete
- About 20 minutes
- Includes
- Company identity, beneficial owners, engagement and payment, government-connection disclosure, compliance program, investigations, sanctions, references, signed certification
Who uses a third-party anti-bribery due diligence form?
- Onboarding a new sales agent or distributor in a higher-risk market
- Renewing due diligence on existing intermediaries each year or two
- Joint venture and teaming partners on a public tender
- Customs brokers, visa agents and licensing consultants
- Exporters who want a consistent record for every partner
- Building an audit trail of what each third party told you and when
Questions on this third-party anti-bribery due diligence form
53 questions over 7 pages · includes signature, file upload, conditional questions, multiple pages, consent checkbox.
1 Your company
- Company's legal name*
- Other names you trade under
- Registration number*
- Country of registration*
- Registered address*
- Website
- Number of employees 1–10 · 11–50 · 51–250 · More than 250
- Contact person*
- Their job title*
- Email*
- Phone*
2 Ownership & management
- How is the company owned?* Privately owned · Listed on a stock exchange · Owned wholly or partly by a government · A subsidiary of another group
- Which exchange, and ticker? asked only when it applies
- Which government body, and what share does it hold?* asked only when it applies
- Parent company and its country asked only when it applies
- Everyone who owns or controls 10% or more*
- Directors and senior managers*
- Ownership chart or register (optional)
3 The engagement
- What will you do for us?* Sales agent or intermediary · Distributor or reseller · Consultant or adviser · Customs, logistics or licensing agent · Supplier or contractor · Joint venture or teaming partner
- Describe the services*
- Countries where you'll act for us*
- How will you be paid? Commission or success fee · Fixed fee · Time and materials · Resale margin
- Will you ask for payment to an account in a different country, or in a different name, from your company?*
- Where, in whose name, and why?* asked only when it applies
- Will you use subcontractors or other third parties for this work?
- Who, and what will they do? asked only when it applies
4 Government connections
- Will your work for us involve dealing with government officials or state-owned companies?*
- Which agencies or companies, and for what?* asked only when it applies
- Is any owner, director, employee or their close family member a current or former government official, political party official, candidate, or employee of a state-owned company?*
- Name of the person* asked only when it applies
- Their role in or link to your company* asked only when it applies
- Government or public position held, the organisation, and the dates* asked only when it applies
- Do they still hold that position? asked only when it applies
- Could they make or influence decisions affecting our business? asked only when it applies
- How do you keep them separate from this work? asked only when it applies
5 Compliance program
- Do you have a written anti-bribery and corruption policy?*
- Upload the policy (optional) asked only when it applies
- Do your staff receive anti-corruption training?
- How often? asked only when it applies At least once a year · When they join · Occasionally
- Do you have rules on gifts, hospitality, donations and facilitation payments?
- Are your financial statements audited by an independent firm?
- Can staff raise concerns confidentially?
- Who is responsible for compliance in your company?
6 History & references
- In the last five years, has the company, or any owner, director or senior manager, been investigated, charged, convicted or sanctioned for bribery, corruption, fraud, money laundering or sanctions breaches?*
- Please give details, including the outcome* asked only when it applies
- Is the company, or any owner or director, named on a sanctions or debarment list?*
- Please give details* asked only when it applies
- Two business references*
7 Certification
- Certification*
- Name of the person signing*
- Title*
- Signature*
- Date*
The third-party anti-bribery due diligence form, page by page
1 Your company
Legal and trading names, registration number and country, registered address, website, size, and the contact person's name, title, email and phone.
2 Ownership & management
"How is the company owned?" Listed asks for the exchange, government-owned asks which body and what share, and a subsidiary asks for its parent. Then "Everyone who owns or controls 10% or more", directors and senior managers, and an optional ownership chart.
3 The engagement
"What will you do for us?", a description of the services, territories, how they'll be paid, whether payment should go to an account in another country or name (yes requires an explanation), and any subcontractors.
4 Government connections
Whether the work involves dealing with officials or state-owned companies, and the connection question. A yes opens the disclosure section: the person, their link to the company, the position and dates, whether they still hold it, whether they could influence decisions, and the safeguards.
5 Compliance program, history & references
A written anti-bribery policy (with an optional upload), training and how often, gifts and facilitation-payment rules, audited accounts, a confidential speak-up route and the compliance lead. Then investigations in the last five years, sanctions or debarment listings, each with required details on a yes, and two business references.
6 Certification
A statement that the signer is authorized, the answers are true, changes will be reported and the information may be checked, followed by name, title, signature and date.
Make the template yours
- Change the ownership threshold to the one your policy uses
- Add questions for your industry, such as export controls or data protection
- Remove the compliance program page for very small, low-risk suppliers
- Ask for a copy of the registration certificate as a required upload
- Notify the compliance inbox and file questionnaires in a restricted folder
- Send the link to each third party from FileIt so you can see who hasn't replied
Tips for a better third-party anti-bribery due diligence form
- Check the answers against independent sources such as company registers and sanctions lists
- Look closely at unusual payment arrangements and high commissions
- Ask follow-up questions when a government connection is disclosed instead of rejecting the partner by default
- Repeat due diligence at renewal or when ownership changes
- Have your program reviewed against the anti-corruption laws that apply to you
Every response becomes a PDF in your vault
The signed questionnaire is filed as a PDF in the vault folder you choose, with the policy and ownership documents attached, and your team is notified by email. The third party receives a copy of what they certified.
The Responses table lists every questionnaire with its answers, so you can filter for disclosed connections or past investigations and export to CSV for your risk register.
- Start from this template. It opens in the FileIt Forms designer — change any question, add pages, set the rules for when questions appear.
- Share it. Turn on a public link, or send it to people by email, each with their own link. They don’t need a FileIt account.
- Get the answers as PDFs. Each response is saved as a PDF in the vault folder you choose, with uploaded files attached — and listed in a Responses table you can export to CSV.
Third-party anti-bribery due diligence form: frequently asked questions
Is this due diligence questionnaire free?
Yes. It's one of the templates included with FileIt's Forms app on every plan, including free.
Does it screen against sanctions lists?
No. It asks the third party to disclose listings. Checking against official lists is a separate step for your team.
Does the third party need a FileIt account?
No. They fill it in from a link or an emailed request.
What happens when someone discloses a government connection?
The form asks for the details your compliance team needs to assess it. What you do next is your decision.
Will this make us compliant with the FCPA or UK Bribery Act?
No form can do that by itself. It's one part of a due diligence process, and it isn't legal advice.
Can I use it for suppliers as well as agents?
Yes. Supplier is one of the roles, and you can shorten the form for lower-risk relationships.