Corporate Criminal Offences Toolkit

Corporate Criminal Offences: Protecting your business

Build your defence to the CCO legislation

The Corporate Criminal Offences Toolkit (CCOT) provides you with everything your organisation needs to build a defence to the CCO legislation, from the CCO Risk Assessment to implementation of next steps. This includes:

• CCO internal policies and procedures
• internal and external communication to employees, suppliers and associated persons
• implementation of new processes (eg due diligence procedures and declaration templates for contractors)
• detailed background on the CCO legislation, advice on how to complete the risk assessment and potential risk areas, guidance on implementing the policies and procedures and next steps

What is in this toolkit?

Comprehensive support and guidance is offered at each stage aligned to HMRC’s ‘Six Guiding Principles’, working through the toolkit will put you in a strong position to develop a CCO defence.

The CCO Toolkit includes the following template documents to assist you in updating your existing controls:

1. Template CCO Risk Register and detailed guidance, including example risk areas
2. Typical CCO Response Implementation Plan
3. Board Paper on CCO
4. Internal CCO Policy, including typical risks to look out for and whistleblowing
5. Internal communication on CCO
6. External comms and contractual terms for suppliers
7. Individual Contractors declaration template
8. Declaration templates for agency workers and contractors
9. Example contractual terms with Suppliers relevant for CCO
10. Internal Supplier Due Diligence Checklist.

There is no de minimis for CCO and it impacts all businesses. We work with organisations across all sectors, from small businesses to global FTSE100s. For larger businesses (non-SMEs), we recommend a detailed review and benchmarking. More information about this product can be found in our brochure.