make your free anti-bribery and corruption policy
what we'll cover
what is an anti-bribery and corruption policy?
when should i use an anti-bribery and corruption policy?
use this anti-bribery and corruption policy:
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to inform your staff about how they should handle any potential bribes and corruption within the workplace
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to comply with your obligations under the bribery act 2010
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to set out the consequences of failing to comply with the rules on anti-bribery and corruption
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if you are a partnership, limited liability partnership (llp) or private limited company only
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if you have staff based in england, wales or scotland
sample anti-bribery and corruption policy
the terms in your document will update based on the information you provide
about anti-bribery and corruption policies
learn more about making your anti-bribery and corruption policy
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how to make an anti-bribery and corruption policy
making your anti-bribery and corruption policy online is simple. just answer a few questions and 2022世界杯32强抽签时间 will build your document for you. when you have all the information about your business and its prevention practices prepared in advance, creating your document is a quick and easy process.
you’ll need the following information:
the business
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is your business a company, a partnership, or an llp?
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what is its name?
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does the business operate in the usa?
the policy
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who has day-to-day responsibility for this policy? you’ll need their job title and email address.
bribery and corruption prevention
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above what value is hospitality considered inappropriate when offered or received by staff?
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above what value are gifts considered inappropriate when offered or received by staff?
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does the business have an expense policy and/or a whistleblowing policy in place?
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if so, are these available online? if so, provide the url.
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can staff members report issues related to bribery and corruption anonymously?
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common terms in an anti-bribery and corruption policy
anti-bribery and corruption policies set out the measures a business takes to prevent bribery and corruption occurring within its operations. to do this, this policy template includes sections headed:
statement of purpose and policy
the policy starts by identifying the business subject to its provisions. it then sets out the reasons why the business is creating the policy and identifies the key relevant legislation (ie the bribery act 2010).
it sets out the business’ key commitments, for example, acting with integrity and enforcing bribery prevention systems.
what does this policy cover?
this section identifies the policy’s scope and character (eg it covers bribery in the uk and abroad and may be changed by the business at any time).
what are bribery and corruption?
this section provides definitions of bribery and of corruption and explains the various things (eg actions) that may constitute either.
who can be involved in bribery and corruption?
this section sets out who this policy applies to. the list includes, for example, the business’ suppliers, clients, and representatives, as well as workers.
in what circumstances can bribery and corruption occur?
information about the common circumstances of bribery is set out here. for example, noting that people involved often have influence over relevant business activities.
who is responsible for this policy?
either the board of directors, designated members, or partners are identified here as having overall responsibility for the policy, depending on your business’ legal structure.
the person with day-to-day responsibility is also identified and other management personnel’s responsibilities are noted.
gifts and hospitality
this section begins with a simple statement that staff are prohibited from soliciting gifts or hospitality in the course of their work for the business.
it also sets out the prohibition on their offering or receiving unduly lavish, extravagant, or otherwise inappropriate gifts or hospitality. it sets out examples of what will be considered such.
keeping records
this section sets out the business’ obligation to keep full financial records to maintain transparency and prevent bribery and corruption. it sets out obligations placed on staff to help achieve this, for example, the requirements to record gifts and hospitality given and received and to submit expense claims.
reporting issues related to bribery and corruption
staff members’ general responsibility to comply with the policy and to prevent bribery and corruption is noted here. so is the requirement that they notify an appropriate person if they witness or experience certain things, for example, being offered a bribe.
consequences of non-compliance
the seriousness of any violations of this policy are set out here, followed by a statement that any staff members who don’t comply with the policy may be subject to disciplinary action and, sometimes, dismissal.
you can edit your document if you want your anti-bribery and corruption policy to include further or more detailed provisions. however, if you do this, you may want a lawyer to review the document for you (or to make the changes for you) to make sure that your modified anti-bribery and corruption policy complies with all relevant laws and meets your specific needs. use 2022世界杯32强抽签时间 ’s ask a lawyer service for assistance.
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legal tips for businesses
make sure everybody complies with your policy and with anti-bribery and corruption laws
having this policy in place is an excellent step towards compliance with the bribery act 2010 and associated laws. however, just having a policy in place is not enough. you must ensure that the provisions in your policy are actually implemented and their effectiveness monitored. you must review and update your policy if required, to ensure it is accurate and up-to-date. you should ensure that staff are aware of their obligations related to the policy and that they know how to meet them.
consider having other relevant policies in place
preventing bribery and corruption is only one part of running a legally compliant and conscientious business. to improve your business’ performance, you should consider creating other workplace policies, for example:
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a whistleblowing policy - to explain when staff members can speak out about injustices in their workplace without fear of detriment
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an environmental policy - to set out how your business works towards being more environmentally sustainable
for information about more policies you may want to put in place as an employer, read hr policies and procedures.
understand when to seek advice from a lawyer
in some circumstances, it’s good practice to ask a lawyer for advice to ensure that you’re complying with the law and that you are well protected from risks. you should consider asking for advice if:
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you work in a regulated sector
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this policy doesn’t meet your needs and you’d like a bespoke version drafted
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you have staff based outside england, wales and scotland
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anti-bribery and corruption policy faqs
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what is included in an anti-bribery and corruption policy?
this anti-bribery policy template covers:
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the purpose of the policy
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who the policy applies to
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definitions of bribery and corruption
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who might be involved in bribery and corruption
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who has responsibility for the policy
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how staff members should report issues related to (potential) bribery and corruption
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how gifts and hospitality should be handled
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record-keeping
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consequences of any breaches of this policy
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do i need an anti-bribery and corruption 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 isn’t a legal requirement, but having one can protect your business by helping it avoid bribery and corruption. by adopting and implementing an anti-bribery and corruption policy, you inform staff of their obligations and 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.
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what are bribery and corruption?
a bribe is an inducement or a reward that 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 promises to provide a financial or another advantage in the future. bribes can be, for example, gifts, hospitality, entertainment, money, or 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.
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who can be involved in bribery and corruption?
bribery and corruption can be committed by a variety of different parties, including:
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any staff (eg employees, directors, zero-hours workers, contractors, interns and volunteers)
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anyone otherwise authorised to act on behalf of your staff (eg someone authorised to act on a company director’s behalf)
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any business representatives or other third parties who act on the business’ behalf (eg a lawyer acting on behalf of the business)
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your suppliers
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your clients or customers
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what are people’s responsibilities relating to bribery and corruption?
this policy sets various restrictions on those who may be involved in bribery or corruption. for example, under this policy, no one should:
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offer or provide a bribe to reward business received, or in the expectation that a business advantage will be received
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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 to someone else)
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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
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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.
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how should gifts and hospitality be handled?
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 gifts or hospitality that is unduly lavish, extravagant or otherwise inappropriate, to or from any person or organisation that has had, has, or may have influence over the business. examples of inappropriate gifts and hospitality include:
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corporate or personal gifts with a value greater than a set amount (based on what is appropriate for the business and industry)
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gifts of cash or cash equivalent (eg vouchers)
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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)
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any hospitality or gifts given or received in secret
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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.
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does it matter where bribery or corruption take place?
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 us foreign corrupt practices act 1977).
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who is responsible for the anti-bribery and corruption policy?
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:
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implementing the policy
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monitoring the policy’s use and effectiveness
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ensuring that the policy is adhered to
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answering any 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. therefore, for:
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companies, the responsibility lies with the board of directors
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llps, the responsibility lies with the designated members
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general partnerships, the responsibility lies with the managing partner(s)
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