1. Purpose and Scope
This policy details the rules [Organisation Name] follows regarding gifts, hospitality, payments, and inducements to ensure full compliance with anti-bribery standards, including the UK Bribery Act 2010.
It applies to everyone acting for or on behalf of [Organisation Name]: employees at all levels, directors, agents, contractors, consultants, and third-party business partners.
The scope covers all business dealings, UK and international, private sector or public officials, whether during or outside working hours.
Working through related paperwork at the same time? See also our Anti-Bribery & FCPA Policy Template, US Anti-Harassment Policy Template and Privacy Notice for Employees Template.
2. Policy Statement
[Organisation Name] strictly prohibits offering, giving, requesting, or accepting bribes, directly or through third parties, for any reason.
We will not participate in business that cannot be conducted honestly and ethically. [Organisation Name] fully supports any team member who loses sales, delays an operational deadline, or forfeits business because they refused to give or receive a bribe.
3. Prohibited Conduct
The following actions are strictly prohibited:
- Offering, promising, or giving anything of value (including money, gifts, hospitality, job offers for relatives, or special favours) to improperly influence a decision.
- Requesting, agreeing to receive, or accepting anything of value in exchange for favourable treatment.
- Bribing a public official, domestic or foreign, directly or through intermediaries.
- Making facilitation payments (small, unofficial payments made to speed up routine administrative tasks).
- Hiring agents, distributors, or business partners to carry out actions prohibited by this policy.
- Concealing improper payments or activities, including falsifying invoices, expense claims, or accounting records.
4. Gifts and Hospitality
Routine, proportionate business hospitality, like working lunches, modest event attendance, or low-value branded items, helps build professional relationships. This is acceptable provided it is transparent, reasonable, and appropriately timed.
Gifts and hospitality must meet the following standards:
- Keep items reasonable in value and occasional. Never offer or accept cash or cash equivalents, such as gift vouchers.
- Never offer or accept gifts or hospitality while a tender, commercial negotiation, or contract renewal involving that party is active.
- Declare any gift or hospitality given or received with an estimated value over [Monetary Threshold] to [Role] for entry into the Gifts and Hospitality Register in [System/Location].
- If you are unsure whether a gift or hospitality item is appropriate, formally declare it.
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5. Facilitation Payments and Donations
Facilitation payments are bribes. They are prohibited under all circumstances, even in regions where they are common practice.
- Duress Exception: The sole exception is when someone demands payment under duress and your personal safety is at immediate risk. In that situation, make the payment, report it to [Role] as soon as you are safe, and document the incident formally.
Charitable donations and sponsorships require prior approval from [Role]. They must go directly to vetted organizations and must never serve to influence a business decision improperly. [Organisation Name] does not make political donations.
6. Responsibilities and Red Flags
- Policy Ownership: [Role] maintains this policy, manages the Gifts and Hospitality Register, and oversees the bribery risk assessment.
- Management Oversight: Line managers must enforce these rules within their teams. They must escalate high-risk arrangements, such as entering new export markets, hiring new agents, or submitting public sector bids, to [Role] before making operational commitments.
- Individual Duty: Everyone must refuse bribes, decline improper requests, and report suspicious activity.
- Red Flags: Watch for indicators of potential bribery, including:
- Demands for cash payments or transfers to unrelated third-party bank accounts.
- Commissions or fees that do not correspond to a clear, legitimate service.
- Intermediaries who insist on secrecy or unusual contract terms.
- Invoices that do not match the goods or services provided.
- Public officials requesting unofficial payments to expedite processes.
7. Raising Concerns and Breaches
Report suspected bribery, extortion, or improper requests to [Role] or through the established whistleblowing procedure.
We investigate all reports confidentially. You will not suffer disciplinary action, commercial detriment, or negative consequences for making a good-faith report or for refusing to pay or accept a bribe.
Breaches of this policy constitute gross misconduct. Violations may result in disciplinary action up to summary dismissal, termination of commercial contracts with third parties, and referral to legal or law enforcement authorities.
8. Training, Records, and Review
- Training: New personnel receive policy training during induction. Staff in high-exposure roles (including procurement, sales, public sector contracting, and overseas operations) must complete refresher training every [Training Frequency].
- Record Keeping: [Role] reviews the Gifts and Hospitality Register every [Review Period].
- Policy Review: [Role] reviews this policy and the associated bribery risk assessment every [Review Frequency], or whenever significant operational changes occur (such as entering new market regions or sales channels).
Policy Owner: [Role] Last Reviewed: [Date] Next Review Due: [Date]
FAQs on an anti-bribery and corruption policy
What is an anti-bribery and corruption policy?
An anti-bribery and corruption policy details the rules your organisation follows regarding gifts, hospitality, payments, and inducements to ensure full compliance with anti-bribery standards, including the UK Bribery Act 2010.
Having it written down means the same rules apply to everyone, so managers are not making judgement calls case by case under pressure.
What does an anti-bribery and corruption policy include?
This template covers prohibited conduct, gifts and hospitality, facilitation payments and donations and raising concerns and breaches.
Every section is written to be filled in. The bracketed placeholders mark the decisions that are yours to make, such as timescales, approval owners and retention periods.
How to implement an anti-bribery and corruption policy with Whale
Copy this template into Whale and work through the bracketed placeholders so it reflects how your organisation actually operates.
Assign it to the teams it applies to so it sits where people work rather than in a shared drive, and set a review date so it gets revisited on schedule instead of quietly going out of date.
Use our templates to fast-track your documentation
Customize this template and 100s of others for free in Whale, the fastest way to get your team aligned.