Purpose and Scope
This policy sets out [Organisation Name]’s rules against bribery and corruption. It applies to all employees, officers, directors, and third parties acting on our behalf, including agents, distributors, consultants, and joint-venture partners. The scope covers every business transaction with government officials or private entities, both domestic and international.
This policy does not constitute an employment contract or change any individual’s employment status. We handle violations under [Disciplinary Policy Name] and may report infractions to law enforcement as required or permitted by law.
Working through related paperwork at the same time? See also our Anti-Bribery & Corruption Policy Template, US Anti-Harassment Policy Template and Privacy Notice for Employees Template.
Prohibited Conduct
The following actions are strictly prohibited:
- Offering, promising, giving, soliciting, or accepting any bribe, kickback, or item of value to improperly influence a business decision. Items of value include cash, gift cards, gifts, travel, entertainment, loans, charitable donations, favors, or job offers for relatives.
- Directing or permitting any third party, agent, distributor, family member, or intermediary to perform a prohibited act on behalf of [Organisation Name].
- Making facilitation payments to speed up or secure routine government actions.
- Falsifying accounting records, hiding payments, or approving mislabeled expenses.
If someone demands payment under threat to your personal safety:
- Pay to protect your immediate physical safety.
- Relocate to a safe place.
- Report the incident immediately to [Role].
Gifts, Hospitality, and Entertainment
Keep gifts, hospitality, and business entertainment modest, occasional, and transparent:
- Any gift given or received must cost less than [Amount], occur infrequently, suit the professional relationship, and never involve cash or cash equivalents.
- Meals and entertainment must support a legitimate business purpose, feature an [Organisation Name] representative as host, and conform to standard local practices [Describe Norm].
- Do not offer or accept gifts, hospitality, or entertainment during active bids, contract negotiations, or renewal discussions with the counterparty.
- You must report any item over [Amount], any interaction involving a government official, or any potential conflict of interest to [Role] and log it in the gift register at [Location/System].
Government Officials and Third Parties
Strict compliance controls apply to public officials and third-party representatives:
- You must obtain written advance approval from [Role] before providing anything of value to a government official, including employees of state-owned entities.
- Third parties representing [Organisation Name] must pass background vetting before engagement to verify ownership, credentials, qualifications, and reasonable compensation rates.
- Pause work with any third party if red flags arise, including requests for above-market commissions, cash payments, transfers to offshore or secondary accounts, government official recommendations, or a history of questionable conduct.
- Include anti-bribery commitments, audit rights, and termination rights for policy breaches in all third-party contracts.
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Books, Records, and Internal Controls
Record all financial transactions accurately, completely, and promptly:
- Document expenses and payments in reasonable detail within the correct account ledger. Do not use off-the-books accounts, misdescribed entries, or unrecorded funds.
- Route approvals according to the authority matrix at [Location].
- Never approve your own business expenses.
- [Role] must verify payments to new payees before processing.
- [Finance Role] will audit the gift register and third-party payments at [Frequency].
Reporting Procedures
To report suspected non-compliance:
- Submit details on suspected bribery, extortion demands, red flags, or falsified records to [Role] or through [Whistleblower Reporting Channel].
- Provide the information required for investigations under [Whistleblower Policy Name].
We strictly prohibit retaliation against anyone reporting a concern in good faith. Nothing in this policy restricts your right to report potential legal violations directly to regulatory authorities.
Training, Recordkeeping, and Review Cycle
- Training: All covered personnel must complete anti-bribery training upon hire and every [Frequency] after that. Staff in high-risk roles or positions dealing with government entities must complete additional specialized training.
- Recordkeeping: Store gift registers, approval records, third-party due diligence files, and training logs at [System/Location] for [Period].
- Review Cycle: We review this policy at [Frequency], following any compliance incident or near miss, and before entering new markets or regions.
Policy Owner: [Role] Next Review Date: [Date]
FAQs on an anti-bribery and FCPA policy
What is an anti-bribery and FCPA policy?
An anti-bribery and FCPA policy sets out your organisation’s rules against bribery and corruption. It applies to all employees, officers, directors, and third parties acting on our behalf, including agents, distributors, consultants, and joint-venture partners.
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 FCPA policy include?
This template covers prohibited conduct, gifts, hospitality, and entertainment, government officials and third parties and books, records, and internal controls.
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 FCPA 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.