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Anti-Bribery Policy Template UK

Anti-Bribery & Corruption Policy Template (UK)

Approx. 6 pages · 17 sectionsBranded PDF + editable WordLast reviewed:

What is a anti-bribery & corruption policy and who needs one?

An anti-bribery and corruption policy sets out your zero-tolerance approach to bribery, gifts and hospitality rules, conflicts of interest and how concerns are reported. It supports the 'adequate procedures' defence to the section 7 Bribery Act 2010 offence and answers the ethics and exclusion questions in public tenders.

Sets out your zero-tolerance approach to bribery, gifts and hospitality, facilitation payments, conflicts of interest and reporting, supporting an 'adequate procedures' approach under section 7 of the Bribery Act 2010.

Why buyers ask for this

Bribery offences are grounds for excluding a supplier under the Procurement Act 2023, and 'adequate procedures' are the main defence to the corporate failure-to-prevent offence, so buyers commonly ask how you prevent bribery.

Who needs it

Commercial organisations can commit the s.7 Bribery Act offence of failing to prevent bribery; having adequate procedures is the defence. Buyers often ask to see your policy.

Where it comes up in a PQQ, SQ or PSQ

Under the Procurement Act 2023, supplier selection uses the Procurement Specific Questionnaire (PSQ) plus each buyer's own conditions of participation and quality questions. Typical questions this policy supports:

  • Mandatory exclusion questions on bribery, fraud and related offences (Procurement Act 2023, Schedule 6)
  • "Provide your anti-bribery and corruption policy and gifts and hospitality register"
  • Conflict of interest declarations required during the procurement
  • – Supports exclusion-ground and ethics questions
  • – Frequently requested for higher-value contracts

What's inside

The full anti-bribery & corruption policy runs to about 6 pages (including the branded cover and document control page) across 17 sections:

  1. Purpose
  2. Scope
  3. Definitions
  4. Prohibited Conduct
  5. Gifts, Hospitality & Entertainment
  6. General Principles
  7. Monetary Limits (example – adjust if you like)
  8. Third Parties, Supply Chain & Procurement
  9. Board of Directors
  10. Bribery Compliance Officer (BCO)
  11. Managers
  12. All Staff and Associated Persons
  13. Raising Concerns (“Speak Up”)
  14. Record-Keeping
  15. Breach of this Policy
  16. Training & Communication
  17. Review

Key points covered

  • Zero-tolerance statement
  • Definitions of bribery
  • Gifts and hospitality rules and register
  • Facilitation payments
  • Conflicts of interest
  • Due diligence on third parties
  • Reporting and whistleblowing
  • Training and review

Every document carries your logo, company name, version number, approval signatory and next review date, in branded PDF plus editable Word.

UK legislation, standards and guidance it references

Excerpt preview

[Your Company Ltd] (“the Company”) is committed to conducting all of its business in an honest, transparent and ethical manner. We have a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. This Policy is designed to help the Company comply with the UK Bribery Act 2010 and related legislation, and to…

Short excerpt. The full policy is generated with your details after purchase.

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How to adapt it

  1. Read every section and remove anything that doesn’t reflect how your organisation actually works.
  2. Complete the bracketed [ADAPT] prompts with your own arrangements, people and data.
  3. Have the policy approved and signed by a director or equivalent, and communicate it to staff.
  4. Keep evidence that you follow it, and review it by the date shown.

Anti-Bribery & Corruption Policy FAQs

What is 'adequate procedures'?

Government guidance describes six principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.

Are facilitation payments allowed under UK law?

No. The Bribery Act 2010 makes no exception for small 'facilitation' or 'grease' payments. The policy prohibits them and explains what staff should do if one is requested.

Does the policy include a gifts and hospitality register?

Yes. It sets out when gifts and hospitality must be recorded and approved, so you can show buyers a clear audit trail.

How much does the Anti-Bribery & Corruption Policy template cost?

£19.99 per policy, or £199 for all 39 policies. It is a one-off payment with no subscription, and you download branded PDF and editable Word files straight away.

Free guides

General information, not legal advice. Requirements differ between buyers and change over time; always check the tender documents.

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