Anti-Bribery Policy for UK business. Bribery Act 2010 s.7 adequate-procedures defence, six MOJ principles, gifts, facilitation payments. From £9.99.
An Anti-Bribery and Anti-Corruption Policy is the written component of a commercial organisation's adequate procedures under section 7 of the Bribery Act 2010. Section 7 creates a strict-liability corporate offence of failing to prevent an associated person from committing bribery on the organisation's behalf — employees, agents, subsidiaries, or anyone else performing services for it. The only defence is adequate procedures: proportionate steps designed to prevent bribery from occurring, in line with the six principles in the Ministry of Justice guidance.
Every UK commercial organisation needs adequate procedures — there is no turnover threshold or headcount minimum. The Bribery Act 2010 applies to any business that operates in the UK or has a business presence there, and has extra-territorial reach covering conduct anywhere in the world. The procedures only need to be proportionate to the risk: a small domestic-only business faces a lower bar than a multinational with overseas supply chains, but the obligation to have adequate procedures exists regardless.
The four offences under the Bribery Act 2010: sections 1 (offering or giving a bribe), 2 (requesting or accepting a bribe), 6 (bribing a foreign public official), and 7 (corporate failure to prevent). The absolute prohibition on facilitation payments — small unofficial payments to speed routine official acts are bribes under UK law even where tolerated locally. The legitimate-versus-prohibited test for gifts and hospitality. Agent and intermediary due diligence. Reporting routes and protection for those who report. Consequences of breach. The six Ministry of Justice adequate-procedures principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.
An Anti-Bribery Policy works best alongside a Whistleblowing Policy: employees who discover or suspect bribery need a safe, protected route to raise the concern internally. The Anti-Bribery Policy generated by Termsmith cross-refers to a Whistleblowing Policy if the employer has one.
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