Bribery — invoice kickbacks (including illegal gratuities)

A vendor pays an employee to approve inflated or fictitious invoices or to steer business to the vendor. In the gratuity variant, a payment or gift is given after an award with no prior agreement.

Partly covered. The remaining analysis is planned.

Starter pack: Disbursement review, Procurement integrity

Red flags

In the data

• Invoiced prices above contract or PO prices
• Vendor spend increases without a change in scope
• One buyer or approver handles most of the vendor's activity

Behavioral

• Employee lifestyle inconsistent with income
• Employee accepts gifts, meals, or travel from vendors
• Employee has unexplained close relationship with a vendor representative

Internal controls

• No vendor gift and entertainment policy or no enforcement
• Invoices not compared to contract pricing
• No rotation of buyer responsibilities