Anti-Bribery Policy

This document sets out an organisation’s approach and expectations in relation to detecting, preventing and responding to bribery and corruption. Read more
Legislation GB-EAW
Topics Updated by a lawyer: 9 Dec 2022

Anti-bribery policy – why is it necessary?

Bribery and corruption are illegal: Bribery and corruption are criminal offences in the UK (and many other countries) and are crucial commercial threats a business needs to safeguard against. Despite their illegality, many firms fall foul of anti-bribery and corruption laws. What’s worse, many of these firms do so without having realised they have crossed legal lines.

Policy sets clear rules for staff: While it goes without saying that a business shouldn’t engage in bribery and corruption, it’s important to outline a firm’s approach, the steps their staff must follow, and the expectations the organisation upholds in relation to these criminal offences. Not only does this allow the business to make its position crystal clear, but it also clarifies the required actions of staff to avoid any legal missteps or general misunderstandings.

Content of anti-bribery policy: An anti-bribery policy sets the foundations for a company’s strategy in dealing with bribery and corruption and explains that bribery and corruption are criminal offences in the UK. It also outlines the firm’s approach to mitigating any instances of bribery and corruption, and the practical steps staff must follow to prevent bribery or corruption within the business. Prevention is certainly better than cure when it comes to bribery and corruption, but an anti-bribery policy must also cover those instances where the line has been crossed.

Important part of compliance: An anti-bribery policy also sets the general tone for the approach of the business to important compliance topics. In other words, if your business hasn't got an anti-bribery policy in place then it is probably an indicator that compliance is an area which requires improvement within the business and needs some attention.

Examples: Examples of bribery might include using company funds to secure preferential treatment, using gifts to avoid scrutiny or any other favours that would unjustly gain favour for the business. One example of a key method for addressing anti-bribery and corruption is to ensure that your anti-bribery policy includes a mandatory and regularly communicated company wide requirement that all hospitality and gifts connected with your business must be promptly declared and recorded within a centrally controlled register or document.

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Legislation GB-EAW
Topics Updated by a lawyer: 9 Dec 2022

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