Written by Policy Pros, UK Policy Writing Specialists at Policy Pros
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Anti-Bribery and Corruption Policy Writers
What Are Anti-Bribery and Corruption Policies?
Anti-bribery and corruption policies set out how organisations prevent, detect and respond to bribery, corruption and other unethical practices. They form a critical part of any organisation's governance framework and are essential for demonstrating compliance with UK law.
Bribery and corruption undermine trust, damage reputations and carry significant legal and financial risks. Under the Bribery Act 2010, it is a criminal offence to offer, promise, give, request or accept a bribe. The Act also creates a corporate offence of failing to prevent bribery by persons associated with the organisation. A clear, well-drafted policy ensures that employees, suppliers and partners understand what behaviour is unacceptable and how to act with integrity in all business dealings.
The Companies Act 2006 further reinforces directors' duties to promote the success of the company and to exercise reasonable care, skill and diligence. This includes ensuring that adequate anti-bribery measures are embedded within the organisation's operations and culture.
The Bribery Act 2010 and the Adequate Procedures Defence
The Bribery Act 2010 is widely regarded as one of the most far-reaching pieces of anti-corruption legislation in the world. It applies to all UK businesses and to any organisation carrying on business in the UK, regardless of where the alleged bribery takes place. The Act created four principal offences: offering or giving a bribe, requesting or receiving a bribe, bribing a foreign public official, and the corporate offence of failing to prevent bribery.
Section 7 of the Bribery Act 2010 introduces the corporate offence of failure to prevent bribery. This is a strict liability offence, meaning that an organisation can be prosecuted if a person associated with it bribes another person with the intention of obtaining or retaining business or a business advantage, even if the organisation's senior management had no knowledge of the bribery. The only defence available to an organisation is to demonstrate that it had adequate procedures in place to prevent bribery.
The Ministry of Justice Guidance on the Bribery Act 2010 sets out six principles that organisations should follow when developing their adequate procedures:
Proportionate procedures - Anti-bribery procedures should be proportionate to the bribery risks faced by the organisation and to the nature, scale and complexity of its activities
Top-level commitment - The board and senior management must foster a culture in which bribery is never acceptable
Risk assessment - The organisation must assess the nature and extent of its exposure to potential external and internal risks of bribery
Due diligence - Proportionate and risk-based due diligence procedures must be applied to persons who perform or will perform services on behalf of the organisation
Communication and training - Anti-bribery policies and procedures must be communicated, embedded and understood throughout the organisation
Monitoring and review - Procedures must be monitored, reviewed and improved where necessary
What Do Anti-Bribery and Corruption Policies Cover?
An anti-bribery and corruption policy typically includes:
A statement of zero tolerance towards bribery, corruption and facilitation payments
Definitions and examples of bribery and corrupt practices, including active and passive bribery
Responsibilities of employees, managers and contractors in upholding the policy
Procedures for declaring and managing gifts, hospitality or conflicts of interest, including thresholds and approval processes
Requirements for due diligence on suppliers, contractors and business partners
Reporting procedures and whistleblowing protections for raising concerns
Disciplinary measures for breaches of the policy
Training and awareness to ensure staff understand risks and obligations
Links to procurement, supplier relationships, whistleblowing and code of conduct policies
Corporate Liability and Risk Assessments
One of the most significant aspects of the Bribery Act 2010 is the extent of corporate liability it creates. An organisation can be held liable for the actions of its employees, agents, subsidiaries and any other associated persons. This means that even if a bribe is paid by a third-party agent without the knowledge of the company, the organisation may still face prosecution unless it can show it had adequate procedures in place.
Conducting regular bribery risk assessments is therefore essential. These assessments should consider the countries in which the organisation operates, the sectors in which it is active, the nature of its business relationships, and the value and complexity of transactions. High-risk sectors such as construction, defence, extractive industries and financial services require particularly robust controls.
A thorough risk assessment should also consider internal risks, including the adequacy of financial controls, the transparency of procurement processes, and the effectiveness of existing compliance monitoring. The results of these assessments should inform the design of anti-bribery procedures and be documented as evidence of the organisation's commitment to compliance.
Sector-Specific Considerations
Different sectors face different bribery risks, and policies should be tailored accordingly. For example, organisations working in the public sector or those engaged in government contracting should be aware of the heightened scrutiny applied to interactions with public officials. The Bribery Act 2010 specifically addresses the bribery of foreign public officials under Section 6, making it an offence to offer an advantage to a foreign public official with the intention of influencing them in their official capacity.
Organisations operating internationally must also consider the interaction between the Bribery Act 2010 and anti-corruption legislation in other jurisdictions, such as the US Foreign Corrupt Practices Act (FCPA). Policies should therefore be designed to meet the highest applicable standard across all territories in which the organisation operates.
Charities, non-governmental organisations and educational institutions are not exempt from these requirements. Any organisation that carries on business in the UK, regardless of its size or sector, should have an anti-bribery and corruption policy that reflects its specific risk profile.
Policy and Procedure Services
We offer a wide-ranging selection of professionally developed workplace policies, designed to meet the practical and legal needs of your organisation. Our policy writing service gives you the flexibility to choose from standard, customised, or fully bespoke documents that align with your business goals, sector requirements, and operational style.
Policy and Procedure Development
Creation of clear, practical policies that reflect current legislation, best practice, and your organisation's values.
Review and Gap Analysis
A thorough review of your existing policies to identify areas for improvement and ensure they remain compliant and effective.
Tailored Solutions
All documents are written in accessible language and adapted to suit your company's size, culture, and ways of working.
Implementation Support
Guidance to help you introduce and embed policies across your organisation so they are understood and applied confidently by all staff.
