Sample Bribery Policy

Bribery Act 2010

Sample Bribery Policy

Your anti-bribery policy should:

Clearly prohibit offering or accepting bribes whether in the UK or abroad.

State that the policy applies to all employees of the company or of third parties acting on behalf of the company.

Set out the procedures that should be followed during business transactions.

Give guidance on the provision of gifts, hospitality or expenses that may influence the outcome of business transactions.

Provide guidance on political and charitable donations, including a prohibition of the payment of donations to political parties or charities that are directly linked to obtaining new business or gaining a business advantage.

Require that any donations made in good faith are publicly disclosed.

Commit to take disciplinary action, including dismissal, and to inform the authorities in the case of any employee or third party accepting or attempting bribery or making facilitation payments.

Require employees to report any concerns to senior management.

Commit to reviewing legislation every 12 months and updating policies and procedures accordingly.

Require that all employees and third parties are made aware of this policy.


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