Anti-Bribery and Corruption Policy

Anti-Bribery and Corruption Policy: Protect Your Business with Clear Rules

An anti-bribery and corruption policy sets out your organisation's zero-tolerance approach to bribery and gives staff and partners practical rules: what counts as a bribe, when gifts and hospitality are acceptable, how to check third parties, and how to report a concern safely. Robot Lawyer drafts the policy from your answers, for the law of the country or state you choose, and on the Verified plan a qualified legal professional checks it within 24 hours before you share it.

CONTENTS

What Is an Anti-Bribery and Corruption Policy?

An anti-bribery and corruption policy is a key part of the procedures an organisation uses to prevent bribery by its staff, agents and other people acting for it. It explains the law in plain terms, sets rules for risky situations such as gifts, hospitality, donations and dealings with public officials, and makes clear that nobody will suffer for refusing to pay a bribe or for raising a concern.

In some countries, including the UK, an organisation can be liable for failing to prevent bribery by people acting for it, unless it has adequate procedures in place. A clear, well-communicated policy is the starting point.

When Do You Need One?

• Businesses bidding for contracts
  Especially public-sector tenders and large supply contracts.
• International trade
  Organisations working in or with higher-risk countries.
• Using agents and intermediaries
  Where third parties win business or deal with officials for you.
• Regulated and high-risk sectors
  Construction, extractives, defence, healthcare, logistics and similar sectors.
• Growing organisations
  When new staff, suppliers and markets increase the risk.

What's Included in Your Policy?

• Policy details
  Your organisation's name and address, who to contact, who owns the policy, its effective date, version and next review date.
• Zero-tolerance statement
  Your commitment from the top.
• What bribery is
  Plain-English definitions with examples, including facilitation payments and kickbacks.
• Gifts, hospitality and expenses
  When they are acceptable, any value limit you choose, approval and recording.
• Donations and conflicts of interest
  Rules on charitable and political donations, and declaring conflicts.
• Third parties and due diligence
  Checks on agents, suppliers and partners.
• Raising concerns
  How to report, confidentiality, anonymous reporting if you allow it, and protection from retaliation.
• Investigations and breaches
  How concerns are investigated and the consequences.
• Optional forms
  A gifts and hospitality register, a third-party due diligence checklist and a bribery concern report form, if you want them.

How It Works on Robot Lawyer

1. Answer the questions
   Tell us where you operate, your risk areas, your gifts rules, your due diligence and how staff can report concerns.
2. Generate your policy
   We draft a clear, practical policy staff and partners can follow.
3. Get it verified
   On the Verified plan, a qualified legal professional checks your policy within 24 hours and makes amendments where needed. The Essentials plan does not include this check. See how our documents are verified.
4. Share it
   Brief staff, include it in induction and share it with agents and key suppliers.

How It Works in Different Countries

• UK
  The Bribery Act 2010 makes it an offence to give or receive a bribe, to bribe a foreign official, and for an organisation to fail to prevent bribery. Facilitation payments are illegal, and having adequate procedures is a defence for organisations.
• United States
  The Foreign Corrupt Practices Act targets bribery of foreign officials and requires accurate books and records for some companies. Federal and state laws also cover domestic bribery.
• Ireland, Australia and Canada
  Each has its own anti-corruption laws covering bribery at home and abroad, and Ireland and Australia can hold organisations liable for bribery by people acting for them.

These notes are general. Check the current rules wherever you do business.

Anti-Bribery Policy FAQs

Are gifts and hospitality allowed?

Usually yes, if they are reasonable, proportionate, given openly and not meant to influence a decision. Your policy sets any value limit and approval rules you choose.

What is a facilitation payment?

A small payment to an official to speed up a routine action, such as a customs clearance. They are illegal in the UK and many other countries, and most policies ban them.

Are we responsible for what our agents do?

Often yes. Many laws can hold an organisation responsible for bribery by people acting for it, so checking and monitoring third parties matters.

Can staff report concerns anonymously?

If you allow it. Your policy explains how to raise a concern, and that nobody will be treated badly for raising one in good faith.

Can I use this policy outside the UK?

Yes. Your policy is drafted under the law of the country or state you choose. Our lawyers are qualified in England and Wales and, on the Verified plan, check documents for good practice, clear formatting and the law of England and Wales. They are not qualified in other countries' law, so if your policy is governed by another country's law, we recommend having a local lawyer check it too.

Create an Anti-Bribery and Corruption Policy

Show your zero-tolerance approach and give your people clear rules. You can start with a 7-day free trial. See our pricing for the plans. Related documents: Whistleblower Policy, Compliance Policy, Expenses Policy and Disciplinary Action Policy.