Anti-Corruption and Bribery Policy

Our Anti-Corruption and Bribery Policy template is suitable for any organisation. It sets out how staff and management should deal with bribery and corruption in the workplace. This is particularly relevant in the UK, since we have one of the world’s most strict anti-bribery laws – the Bribery Act 2010.

About our Anti-Corruption and Bribery Policy Template

When you put this policy in place (and of course ensuring it is enforced in practice), it is a good step in the direction of ensuring that:

• you rule out bribery and corruption in your workplace, and
• your company is not prosecuted for breach of the Bribery Act 2010.

As part of the Bribery Act it is a legal requirement that every business has in place a policy, to help avoid bribery taking place – this policy will ensure you comply with that requirement as a start. For more about the UK’s anti-bribery laws and the need for this anti-bribery policy, read our guide here.

The Anti-Corruption and Bribery Policy is comprehensive and covers:

• what bribery is;
• the rules on banning bribery; and
• what modest gifts and hospitality may be acceptable, whether given or received.

Other HR Handbook documentation from Legalo

Legalo has a full range of policies for your HR Handbook if you need individual policies or you can buy the complete set at a significant discount on the price of buying them individually. Click here for full details.

Clauses in this Anti-Corruption and Bribery Policy

The excerpt from the guide to this template below sets out the main features of this Anti-Corruption and Bribery Policy, so you have an idea what it covers:

Policy outline

This section sets out what the purpose of the policy is and the consequences of breaching it.

Application of this policy

This section sets out how this policy applies. It applies to all contractors and agents of the business, as well as employees.

Definition of bribery

This section in the anti-corruption and bribery policy sets out what bribery is or can be. This follows the definition in the Bribery Act. So, as you can see, a lot of behaviour could be caught by it for any business operating in or out of the UK (even where the act is carried out overseas). It is notable that “facilitation payments”, while lawful in the US, are illegal under English law. Also at the end of the list of examples, you can add any others that your business might find relevant or be susceptible to, based on your specific industry. If there are none, then delete the final bullet point.

Business hospitality

This section in the anti-corruption and bribery policy sets out how reasonable gifts and hospitality:

• can be given or received, and
• would not then count as bribery.

Ethical record-keeping

To prevent false record-keeping which might hide bribery, this section makes it mandatory to keep accurate records. It would be a disciplinary offence to breach this. In the second paragraph of this section, if you do not have an expenses policy, then delete reference to this or consider purchasing a template for one from Legalo’s website.

Raising concerns

This section in the anti-corruption and bribery policy sets out that employees can raise concerns and suspicions about possible bribery with the business in a secure and confidential manner, knowing no one will victimise them as a result (in accordance with the whistle-blowing policy, which has more detail on this). If you do not have a whistle-blowing policy, then delete reference to this or consider buying a template for one from our website.