Anti-Bribery and Corruption Policy

What is a UK Anti-Bribery and Corruption Policy?

An anti-bribery and corruption policy template is an internal company policy used to identify, manage, investigate and prevent incidents of corruption and bribery at the workplace. This is a popular corporate policy template used frequently by the UK businesses operating in both public and private sectors.

A standard anti-bribery, gifts and hospitality policy template outlines the following:

• list of unsolicited behaviour;
• reporting procedure;
• list of categories of employees to whom the policy shall apply; and
• list of employees responsible for the proper implementation of the policy.

This template of anti-bribery policy is widely used by charities, fundraising organisations, businesses participating in public procurement procedures and tenders, SMEs and other organisations operating in the UK.

What should be included in this anti-corruption policy template?

A standard anti-bribery and gift acceptance policy template should clearly outline:

General Provisions

The text of the policy usually includes:

• full name of the employer, including business registration number as per Companies House;
• list of categories of employees to whom this policy applies (for example, remote employees can be excluded);
• full name, job title and contact details of a person within the organisation responsible for the implementation of this policy; and
• date of adoption of this policy.

In a situation when the employer has to perform prior consultation with third bodies such as trade unions before the implementation of such a policy, the full name of such a third party should also be stated in the policy.

Compliance Clause

The text of the sample gift acceptance policy template should confirm its compliance with the applicable UK laws, including the UK Anti-Bribery Act 2010. In case of a global anti-bribery and corruption policy, the policy should also comply with the legislation of other countries and jurisdictions where the company operates.

Guarantee Clause

A standard example of a sample gift acceptance policy must include additional guarantees for employees, ensuring their legal protection.

First, the employer should not terminate or threaten to terminate employment relations with the employee in case they submit their concern under this policy.

Second, the employer must not victimise any employee who raises a concern under this policy.

Finally, the employer cannot disclose the identity of the employee making a disclosure under this policy without the employee’s prior written consent.

List of Unsolicited Behaviour

A solid and well-written anti-bribery and anti-corruption policy​ template should clearly outline a list of actions that are prohibited and not acceptable within the workplace or during the performance of the working duties. These types of behaviour may include:

• accepting or making facilitation payments;
• accepting gifts or hospitality from third parties for the total amount exceeding the established threshold;
• committing a fraud;
• conceiving of any of the actions listed above, etc.

It is advisable to include as many examples of unacceptable conduct as possible to ensure the employees are well informed of the types of behaviour prohibited under this policy.

Investigation and Reporting

Another important pillar of the anti-bribery and gift policy template​ is the inclusion of a detailed procedure for identifying, addressing and managing incidents under this policy. Therefore, the policy should outline the following:

• Who the complaint should be submitted to;
• List of specifically assigned employees to whom the complaint can be submitted;
• List of information that should be included in the complaint;
• Timeline within which a complaint should be investigated.

Gifts and Hospitality Policy vs Anti-Bribery and Corruption Policy

These two documents are being widely used by UK employers to ensure workplace compliance.

You may have already noticed that some UK employers may have only one or two documents at the same time. A gift acceptance policy template is a short corporate policy used to address specifically rules and regulations related to the acceptance of gifts and hospitalities by employees from the contractors, agents or third parties.

On the other hand, the template for the anti-corruption and bribery policy is a much broader document that focuses on different unfair and unethical business practices. While gifts and hospitality are also being covered by it, a solid anti-corruption and bribery policy also includes facilitation payments, kickbacks, fraud, etc.

The type of policy required depends on the type of activity your business performs and the extent to which your employees interact with providers, customers, agents and contractors, as well as other factors.

Why Do UK Businesses Use Written Anti-Corruption Procedures?

Today many UK companies, no matter their size, choose to have a written anti-bribery and corruption policy at the workplace.

Compliance

The UK Bribery Act 2010 adopts a strong legal framework aimed to combat corruption and bribery in both public and private sectors. The established legal framework imposes the obligation of transparency on all businesses and companies performing their activity in the UK.

In this regard many UK employers want to create a safe and compliant workplace environment to ensure that their employees remain fully compliant with the requirements of the Bribery Act while performing their work duties.

Corporate Culture

Implementation of an anti-bribery and anti-corruption policy at the workplace ensures transparency and increases professional standards of behaviour amongst employees. With the help of a gift policy template, employees are clearly aware of which gifts are acceptable and which are not.

This is particularly important for global anti-bribery and corruption policies that are being implemented by organisations operating in different countries and regions.

Responsibility

The template of the anti-bribery and corruption policy​ clarifies consequences for employees, staff and employers in case of a failure to comply with this policy. The document helps:

• to define what is expected from employees;
• to stipulate legal consequences for violation of the policy (dismissal, warnings); and
• to improve internal corporate governance with the sole aim of preventing cases of non-compliance in the future.

How to customise this template for your business?

To get a fully customisable gift, anti-bribery and corruption policy template, follow a few easy steps:

1. Click the “Create Document” button.
2. Answer simple questions in the form.
3. Select a template’s format – anti-bribery and corruption policy PDF or Word.
4. Make a payment.

The document is ready for immediate implementation and usage within the organisation.