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How to make an Anti bribery and corruption policy

Create an anti bribery and corruption policy to set out how your business prevents bribery and corruption from occurring in the workplace.

Recently reviewed by Adnan Mahmood, Solicitor and Head of Legal, UK. 

This postnuptial agreement was last reviewed on 18 November 2022.

An anti bribery and corruption policy is a document that sets out your business’ approach towards bribes and corruption. Anti bribery policies are used to set out the rules and procedures staff should follow when handling potential bribes.

Use this anti bribery and corruption policy template:

This anti bribery policy template covers:

  • the purpose of the policy

  • who the policy applies to

  • what bribery and corruption are

  • who can be involved in bribery and corruption

  • who has responsibility for the policy

  • how to report issues related to (potential) bribery and corruption

  • how gifts and hospitality should be handled

  • record-keeping

  • consequences of a breach of this policy

Under the Bribery Act 2010, it is illegal to offer, promise, give, request, agree, receive or accept bribes. Having an anti bribery and corruption policy in place can protect your business by helping it avoid bribery and corruption. By adopting and implementing an anti bribery and corruption policy you not only inform staff of their obligations, but you also prevent them from spoiling your business’ reputation by accepting bribes. 

You should have an anti bribery and corruption policy if there is a risk that someone who works for you (or on your behalf) may be exposed to bribery. Keep in mind that exposure to bribery could be as simple as attending a client dinner. 

For more information, read Workplace anti-bribery rules.

A bribe is an inducement or a reward one person makes to another to gain an advantage (eg a prospective business partner offering a lavish gift to a company director to gain a contract). Bribes include any promise to provide a financial or another advantage in the future, such as gifts, hospitality, entertainment, money and preferential treatment.

Bribery is the act of making, receiving, requesting or offering a bribe. 

Corruption is the misuse of power or office for private gain.

For more information, read Workplace anti-bribery rules.

Bribery and corruption can be committed by a variety of different parties, including:

  • any staff (eg employees, directors, zero-hours workers, contractors, interns and volunteers)

  • anyone otherwise authorised to act on the behalf of your staff (eg someone authorised to act on a company director’s behalf)

  • any business representatives and other third parties who act on the business’ behalf (eg a lawyer acting on behalf of the business)

  • your suppliers

  • your clients or customers

Under this policy, no one should:

  • offer or provide a bribe to reward business received, or in the expectation that a business advantage will be received

  • accept an offer that they know or suspect to be made with the expectation that it will provide a business advantage (to the bribing party or someone else)

  • offer or provide a payment to a government official in any country (in the UK or abroad) to facilitate or speed up a necessary or routine procedure

  • otherwise fail to prevent bribery and corruption from occurring

If your business operates in a sector that has specific anti-bribery and corruption requirements or an anti-bribery and corruption framework, you should set this out as part of this policy. To do this, edit your document or Ask a lawyer for drafting assistance.

Under this policy, staff are not allowed to solicit gifts or hospitality in the course of their work. They are also prohibited from offering or receiving a gift or hospitality which is unduly lavish, extravagant or otherwise inappropriate, to or from any person or organisation which has had, has, or may have influence over the business. Examples of inappropriate gifts and hospitality include:

  • corporate or personal gifts with a value greater than a set amount (based on what is appropriate for the business and industry)

  • gifts of cash or cash equivalent (eg vouchers)

  • hospitality (eg refreshments, working lunches or entertainment costs for (prospective or current) business partners or clients) to a value greater than a set amount (based on what is appropriate for the business and industry)

  • any hospitality or gifts given or received in secret

  • any hospitality or gifts received in the name of an individual rather than in the name of the business

In order to ensure full transparency related to gifts and hospitality, it is a good idea to have a clear Expense policy in place. This policy should outline how staff can recover any expenses related to gifts or hospitality. 

Staff should also make sure to declare and properly record in writing all hospitality and gifts they receive or give.

Under this policy, it does not matter whether an act of bribery or corruption within the business takes place in the UK or abroad. Under the Bribery Act 2010, any act of bribery or corruption committed outside of the UK may be prosecuted in the UK. It is worth noting that, if a business has a trading presence in the USA, any acts of bribery or corruption may also be prosecuted in the USA under similar bribery and corruption legislation (ie the Foreign Corrupt Practices Act 1977).

While all staff are responsible for preventing bribery and corruption within your business, one person (eg a compliance manager) should have day-to-day responsibility for this anti bribery and corruption policy. This person will be responsible for:

  • implementing the policy

  • monitoring the policy’s use and effectiveness

  • ensuring that the policy is adhered to

  • answering staff questions about bribery and corruption

Overall responsibility for preventing bribery and corruption within a business lies at the most senior level of the business. This means that for: 

  • companies, the responsibility lies with the board of directors

  • LLPs, the responsibility lies with the designated members

  • general partnerships, the responsibility lies with the managing partner(s)

Ask a lawyer if:

  • you work in a regulated sector

  • this policy doesn’t meet your needs and you’d like a bespoke version drafted

  • you have staff based outside England, Wales and Scotland

This anti bribery and corruption policy complies with the laws of England, Wales and Scotland.

Other names for Anti bribery and corruption policy

Anti bribery policy, Anti-bribery policy, Anti-corruption and bribery policy, Anti-bribery and corruption policy, Anti corruption policy, Anti corruption and bribery policy, ABC policy.