Anti Bribery Policy Template UK

Bribery is a severe issue that can corrupt businesses and harm individuals. Having a strong anti-bribery policy is one of the best ways to prevent bribery. It helps organizations comply with the law, protect their reputation, and uphold ethical standards. This article provides a comprehensive anti-bribery policy template for UK businesses. This template covers essential elements to effectively address bribery risks.

The UK Bribery Act 2010 is a comprehensive anti-bribery legislation that makes it illegal for businesses to offer, promise, or accept bribes. It also mandates businesses to prevent bribery by implementing adequate procedures. An anti-bribery policy is a crucial step in fulfilling this legal requirement. Furthermore, adopting an anti-bribery policy demonstrates an organization’s commitment to ethical practices and strengthens its reputation among customers, investors, and other stakeholders.

Anti Bribery Policy Template UK

Elements of an Effective Anti-Bribery Policy

Policy Statement

The policy statement is the introductory section of the policy that sets the tone and purpose of the document. It should clearly state the organization’s commitment to preventing bribery and adhering to all applicable anti-bribery laws and regulations. The policy statement should be concise, easy to understand, and signed by a senior executive to demonstrate top-level support.

Prohibition of Bribery

This section should explicitly prohibit all forms of bribery, both active and passive. Active bribery refers to offering, promising, or giving a bribe, while passive bribery involves requesting, agreeing to receive, or accepting a bribe. The policy should emphasize that bribery is illegal and unethical and that any employee or associated person found engaging in bribery will face disciplinary action.

The policy should also define what constitutes a bribe. It should clarify that a bribe is not limited to monetary payments but can also include gifts, favors, hospitality, or any other benefit offered or received to influence a business decision. This broad definition ensures that all potential forms of bribery are covered.

Gifts and Hospitality

The policy should provide guidance on acceptable gifts and hospitality. It should set limits on the value and frequency of gifts and hospitality that can be offered or accepted. The policy should also specify who is authorized to offer or accept gifts and hospitality and the circumstances under which they can be exchanged.

The policy should prohibit employees from accepting gifts or hospitality from suppliers, customers, or other third parties that could create a conflict of interest or appear to influence business decisions. The policy should also discourage employees from offering gifts or hospitality that may be perceived as an attempt to bribe.

Implementation and Monitoring

Training and Awareness

The policy should require all employees to undergo regular training on anti-bribery policies and procedures. Training should cover the definition of bribery, the organization’s anti-bribery policy, and the consequences of violating the policy. The training should also provide practical guidance on how to avoid bribery risks in everyday business situations.

Due Diligence on Third Parties

The policy should require the organization to conduct due diligence on third parties, such as agents, distributors, and suppliers, before entering into business relationships. Due diligence should aim to identify any potential bribery risks associated with the third party. The organization should also monitor the third party’s activities and terminate the relationship if any bribery concerns arise.

Reporting and Investigation

The policy should establish a clear procedure for reporting suspected bribery. Employees should be encouraged to report any suspected bribery incidents to the appropriate authority within the organization. The policy should also outline the process for investigating reported incidents and the consequences for those found responsible for bribery.

Record Keeping

The policy should require the organization to maintain accurate records of all gifts and hospitality offered or accepted, as well as any payments made to third parties. These records should be retained for a specified period to facilitate investigations and audits. The policy should also specify who is responsible for maintaining these records and how they should be stored.


Having a robust anti-bribery policy is essential for UK businesses to comply with the law, protect their reputation, and uphold ethical standards. This article provided a comprehensive anti-bribery policy template that covers key elements such as policy statement, prohibition of bribery, gifts and hospitality, implementation, and monitoring. By adopting this template, UK businesses can effectively address bribery risks and demonstrate their commitment to ethical practices.

Implementing an anti-bribery policy is an ongoing process that requires continuous monitoring and review. Organizations should regularly review their policy to ensure it remains effective and up-to-date with changes in the law and best practices. This commitment to continuous improvement demonstrates the organization’s dedication to maintaining a culture of integrity and preventing bribery.


What is the purpose of an anti-bribery policy?

An anti-bribery policy aims to prevent bribery by setting out clear guidelines for employees and associated persons. It helps organizations comply with the law, protect their reputation, and uphold ethical standards.

What are the key elements of an effective anti-bribery policy?

Key elements include a policy statement, prohibition of bribery, guidance on gifts and hospitality, implementation and monitoring mechanisms, and procedures for reporting, investigating, and recording suspected bribery incidents.

Who should be responsible for implementing an anti-bribery policy?

The responsibility for implementing an anti-bribery policy typically lies with senior management. However, all employees should be aware of the policy and their role in preventing bribery.

How can organizations ensure the effectiveness of their anti-bribery policy?

Organizations can ensure the effectiveness of their anti-bribery policy by providing regular training, conducting due diligence on third parties, establishing clear reporting and investigation procedures, maintaining accurate records, and reviewing the policy regularly to keep it up-to-date.

What are the consequences of violating an anti-bribery policy?

Violating an anti-bribery policy can lead to disciplinary action, legal penalties, reputational damage, and loss of business opportunities.