Third-Party and Supplier Due Diligence
Create a structured due diligence process for assessing integrity risks in suppliers, partners, and service providers.
Implement a third-party verification process that identifies corruption, money laundering, and reputational risks before formalizing commercial relationships.
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Prompt objective
Implement a third-party verification process that identifies corruption, money laundering, and reputational risks before formalizing commercial relationships.
Real use case
IndustriaAlimentos SA, a processed food exporter from Paraná, was notified by the CGU (Brazil's federal comptroller general) after one of its distributors became implicated in a corruption investigation. The company needs to implement due diligence across its 340 suppliers and 28 distributors.
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Prompt
Create a complete third-party integrity due diligence process for [COMPANY NAME], operating in the [SECTOR] industry, with [NUMBER] suppliers and [NUMBER] commercial partners.\\\\\\\\n\\\\\\\\n**Context:**\\\\\\\\n- Exports to: [COUNTRIES]\\\\\\\\n- Regulators: [AGENCIES]\\\\\\\\n- Previous incidents: [DESCRIBE OR N/A]\\\\\\\\n\\\\\\\\n**Structure the process in 4 phases:**\\\\\\\\n\\\\\\\\n1) **Third-Party Risk Classification**:\\\\\\\\n - Categorization criteria (low/medium/high risk)\\\\\\\\n - Weighting factors: contract value, government interaction, country of origin, industry\\\\\\\\n - Decision matrix: due diligence level by category\\\\\\\\n\\\\\\\\n2) **Information Gathering** (checklist by level):\\\\\\\\n - **Level 1 (Basic)**: Business registration, negative certificates (Federal, State, Municipal, Labor, FGTS—pension fund), CEIS/CNEP/CEPIM database checks (Brazilian debarment lists)\\\\\\\\n - **Level 2 (Intermediate)**: Ownership structure (up to 3 levels), PEP check, negative media coverage, litigation search (State and Federal courts, Labor courts)\\\\\\\\n - **Level 3 (Enhanced)**: On-site visit, management interviews, financial analysis, third-party compliance verification\\\\\\\\n\\\\\\\\n3) **Analysis and Decision**:\\\\\\\\n - Automatic red flags (list of 15+ warning signs)\\\\\\\\n - Approval committee: composition by risk level\\\\\\\\n - Decision documentation (approve/reject/approve with mitigation)\\\\\\\\n - Mandatory anti-corruption clauses in contracts\\\\\\\\n\\\\\\\\n4) **Continuous Monitoring**:\\\\\\\\n - Reassessment frequency by risk level\\\\\\\\n - Extraordinary reassessment triggers\\\\\\\\n - Monitoring indicators (compliance KPIs)\\\\\\\\n\\\\\\\\n**Deliverables:**\\\\\\\\n- Third-party registration form\\\\\\\\n- Integrity questionnaire (self-assessment)\\\\\\\\n- Due diligence report template\\\\\\\\n- Approval process flowchart\\\\\\\\n\\\\\\\\nBase this on Brazil's Anti-Corruption Law (Law 12,846/2013), Anti-Money Laundering Law (Law 9,613/1998), and FCPA/UK Bribery Act standards when international operations are involved.
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