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The Corruption Risk Assessment and Mitigation Plan is a crucial compliance document required for organizations operating in India's complex regulatory environment. It is particularly essential following the 2018 amendments to the Prevention of Corruption Act, which introduced corporate liability for corruption offenses. This document should be implemented when an organization needs to systematically identify and address corruption risks, establish robust internal controls, and demonstrate compliance commitment to regulatory authorities. The plan typically includes comprehensive risk assessment methodologies, detailed mitigation strategies, clear reporting procedures, and monitoring mechanisms. It addresses both domestic Indian compliance requirements and, where applicable, international anti-corruption standards. The document is especially vital for organizations operating in high-risk sectors, dealing with government officials, or managing complex supply chains within India's business landscape.

1. Parties: Identification of the organization(s) covered by the plan and key stakeholders responsible for implementation

2. Background: Context of the organization's operations, regulatory environment, and purpose of the risk assessment and mitigation plan

3. Definitions: Key terms used throughout the document, including types of corruption, risk levels, and compliance-related terminology

4. Scope and Objectives: Clear delineation of what the plan covers, including geographical scope, business units, and specific objectives

5. Risk Assessment Methodology: Detailed explanation of how corruption risks are identified, assessed, and prioritized

6. Risk Assessment Findings: Summary of identified corruption risks, their likelihood, impact, and current control effectiveness

7. Mitigation Strategies: Comprehensive plan for addressing identified risks, including specific controls and preventive measures

8. Roles and Responsibilities: Clear assignment of responsibilities for risk assessment and mitigation activities

9. Monitoring and Review: Procedures for ongoing monitoring of mitigation measures and periodic review of the plan

10. Reporting and Escalation: Protocols for reporting corruption incidents and escalating concerns

11. Training and Communication: Requirements for staff training and communication of anti-corruption policies

12. Documentation and Record Keeping: Procedures for maintaining documentation of risk assessment and mitigation activities