Anti-Bribery and Corruption Policy

A complete anti-bribery policy for a UK business. It sets out what staff and anyone acting for you must and must not do, how gifts and hospitality are approved and recorded, and the checks you carry out on agents, suppliers and partners. Together with the appendices it is the core of your “adequate procedures” under section 7 of the Bribery Act 2010.

• Every business – the section 7 offence applies to companies and partnerships of any size
• When customers, banks or public sector buyers ask for your anti-bribery policy
• When you use agents, introducers or overseas partners, or deal with public officials

• Fill in your name, Compliance Officer and the gift and hospitality limits in section 7
• Complete the risk assessment in Appendix C before you finalise the policy
• Brief every member of staff and keep signed acknowledgements (Appendix F)
• Keep the register in Appendix B up to date and review it every quarter