Due diligence questionnaire for agents, brokers and introducers

Use this before you appoint or first pay any agent, distributor, broker, introducer, consultant or other intermediary, and again every year. Keep the completed form, supporting documents and your decision. Someone senior, who is not the person who wants to appoint them, signs it off.

Who completes it: the intermediary. Who reviews it: [policy owner]. Date: ________

Part 1. Who they are

Question	Answer
Full legal name, legal form and registered number
Registered address and country of incorporation
Trading names
Directors, owners and anyone holding 25% or more, with nationalities
Does any owner, director or employee hold, or recently hold, a public office, or is related to someone who does?
Does any owner, director or employee also work for, or have a financial interest in, a customer or competitor of ours?
How long have they traded, and what is their business?
Bank account to be used: bank, country, and name on the account. It must be in the legal name of the company, in the country where the services are provided.

Part 2. What they will do

Question	Answer
Precisely what services will they provide for us?
Why do we need an intermediary for this?
In which countries and with which customers will they work?
How are they paid, how much, and how was the rate decided? Is it in line with the market for the service?
Will they or we pay anyone else out of the fee, or share it?
Do they act for any customer as well? If so, does that customer know they are paid by us?

Part 3. Their conduct and policies

Question	Answer
Does the company have a written anti-bribery policy? Please attach it.
Do staff receive training on it? How often?
Has the company, or any director or owner, ever been investigated, charged or convicted for bribery, corruption, fraud or money laundering, or been excluded from a tender or an association? If yes, give details.
Does the company accept or pay gifts, hospitality, commissions or other benefits in connection with orders? What are its rules?
Does the company disclose any commission or benefit it receives on a transaction to the person whose money is being spent? How?
Who in the company is responsible for compliance?
How do staff raise concerns, and are they protected?

Part 4. Declarations

The signatory confirms that:

1. The information above is complete and accurate, and the company will tell [Company name] promptly of any change.
2. The company will comply with [Company name]'s anti-bribery policy and the law, and will not offer, promise, give, ask for or accept any improper benefit in connection with the services.
3. The company will not keep any commission, discount or benefit secret from the person whose money is being spent, and will not ask [Company name] to do so.
4. The company agrees to the anti-bribery clauses in its contract, including the right to audit and to end the contract for breach.

Signed: ____________ Name and position: ____________ Date: ________

Part 5. Our review

Check	Result	Initials
Identity and company registration verified from an independent source
Owners and directors checked against sanctions and adverse media
Bank account name and country match the contract
Fee reasonable for the service, and not paid in cash or to a third party
Red flags (tick any): ☐ request for payment to an individual or offshore account ☐ fee out of proportion ☐ vague services ☐ request for secrecy ☐ recommended by a customer's decision-maker ☐ refusal to answer questions ☐ pressure or urgency
Decision: ☐ Approve ☐ Approve with conditions ☐ Decline
Approved by (not the sponsor):

Review again by: ________

General information, not legal advice.