Use this template to create an anti-bribery policy.

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Anti-Bribery Policy

[Company Name]

Policy Owner: [Managing Director/Compliance Officer] Last Reviewed: [Date] Next Review: [Date]

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1. Policy Statement

[Company Name] has a zero-tolerance approach to bribery and corruption. We are committed to conducting business ethically and in compliance with the Bribery Act 2010 and all applicable anti-bribery laws.

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2. Purpose

This policy:

• Sets out our position on bribery
• Provides guidance on recognising and avoiding bribery
• Establishes procedures for reporting concerns
• Helps protect the Company, our employees, and our reputation

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3. Scope

This policy applies to:

• All directors, officers, and employees
• Contractors, consultants, and agency workers
• Agents, intermediaries, and third parties acting on our behalf
• All business dealings worldwide

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4. What is Bribery?

4.1 Definition

Bribery is offering, promising, giving, requesting, or accepting a financial or other advantage to induce or reward improper performance of a function.

4.2 Offences Under the Bribery Act 2010

Offence	Description
Bribing another person	Offering, promising, or giving a bribe
Being bribed	Requesting, agreeing to receive, or accepting a bribe
Bribing a foreign public official	To obtain or retain business
Failure to prevent bribery	Corporate offence for organisations

4.3 Examples of Bribery

Bribery may include:

• Cash payments or kickbacks
• Excessive or lavish hospitality
• Gifts intended to influence decisions
• Political or charitable contributions made to gain advantage
• Facilitation payments (illegal under UK law)
• Offering employment to influence decisions

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5. Gifts and Hospitality

5.1 Principles

Modest gifts and hospitality are a normal part of business relationships. However, they must:

• Be reasonable and proportionate
• Not be intended to influence decisions
• Not create a sense of obligation
• Be transparent and recorded

5.2 Acceptable Examples

Generally Acceptable	Generally Not Acceptable
Modest business meals	Lavish entertainment
Small promotional items	Cash or cash equivalents
Reasonable hospitality at events	Gifts to influence decisions
Modest seasonal gifts	Hospitality during procurement

5.3 Approval Requirements

Value	Requirement
Under £[50]	No approval required, record in register
£[50]-£[250]	Manager approval required
Over £[250]	Senior management approval required

5.4 Register

All gifts and hospitality (given or received) over £[25] must be recorded in the Gifts and Hospitality Register, available from [location].

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6. Facilitation Payments

Facilitation payments are small payments made to speed up routine government actions (e.g., processing permits).

Facilitation payments are illegal under UK law and are prohibited.

If you are asked for such a payment, refuse and report it immediately.

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7. Political and Charitable Contributions

• Political donations must be approved by [the Board]
• Charitable donations must not be made to secure business advantage
• All significant donations must be approved and recorded

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8. Third Parties

8.1 Due Diligence

Before engaging agents, intermediaries, or other third parties, we must:

• Conduct proportionate due diligence
• Assess the bribery risk
• Ensure they understand our anti-bribery requirements

8.2 Contracts

Contracts with third parties should include anti-bribery provisions where appropriate.

8.3 Monitoring

Third-party relationships should be monitored for bribery red flags.

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9. Red Flags

Be alert to warning signs including:

Red Flag	Example
Unusual payment requests	Cash, to third parties, to unusual locations
Excessive commissions	Unusually large agent fees
Lack of transparency	Refusal to provide information
High-risk locations	Countries with corruption concerns
Pressure for urgency	Demands for immediate decisions
Vague services	Unclear what is being paid for

If you encounter red flags, stop and seek guidance.

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10. Record Keeping

We must maintain accurate records of:

• Financial transactions
• Gifts and hospitality
• Third-party due diligence
• Training undertaken

Records must be:

• Accurate and complete
• Retained for [6] years minimum
• Available for audit

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11. Responsibilities

11.1 All Employees

• Comply with this policy
• Report concerns or suspicions
• Complete required training
• Maintain accurate records

11.2 Managers

• Ensure team awareness
• Monitor compliance
• Address concerns raised
• Lead by example

11.3 Senior Management

• Demonstrate commitment from the top
• Ensure adequate resources for compliance
• Review policy effectiveness

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12. Reporting Concerns

12.1 How to Report

If you suspect bribery, report it to:

• Your manager
• [Compliance Officer]
• Via the Whistleblowing Policy

12.2 Protection

You will not be penalised for reporting genuine concerns in good faith. We will protect you from retaliation.

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13. Consequences of Breach

Breach of this policy is a serious disciplinary matter that may result in:

• Disciplinary action up to dismissal
• Personal criminal liability
• Reputational damage

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14. Training

All employees will receive anti-bribery training appropriate to their role. Training will be refreshed [annually/as needed].

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15. Review

This policy will be reviewed annually or when there are significant changes to the business or legislation.

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Key Contacts

Role	Name	Contact
Compliance Officer	[Name]	[Contact]
Whistleblowing contact	[Name]	[Contact]

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Document Control

Version	Date	Author	Changes
1.0	[Date]	[Name]	Initial version