Anti-corruption and Bribery Policy

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Companies must act in an honest and ethical manner and in the UK are bound by the Bribery Act 2010 in respect to their conduct both at home and abroad. A business should have a zero tolerance approach to bribery and corruption and can adopt an anti-corruption and bribery policy to ensure that they act professionally, fairly and with integrity in all business dealings and relationships. A company's policy will outline systems for countering bribery and corruption.


Why is an anti-bribery policy important?

A policy is important as it increases compliance with anti-bribery laws by setting out a company's responsibilities in observing and upholding its position on bribery and corruption and by providing information and guidance to workers in terms of how to recognise and deal with bribery and corruption issues.


Who does the anti-bribery policy apply to?

This anti-bribery policy applies to all persons working for the company or any group company or on the company's behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with the company, wherever located.

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Who is responsible for the anti-bribery policy?

The board of directors has overall responsibility for the effective operation of the anti-bribery policy and line managers have day-to-day responsibility for the policy.


What are the key terms of the anti-bribery policy?

In order to ensure compliance with anti-bribery laws, an anti-bribery policy should contain the following key terms:

  • What you must not do: examples of what a worker must not do include giving or accepting gifts, making unofficial payments to government officials.
  • Facilitation payments and kickbacks: kickbacks are typically payments made in return for a business favour or advantage.
  • Gifts, hospitality and expenses: giving and accepting gifts may be permitted under certain circumstances, for example if they are not made with the intention of influencing a third party to obtain or retain business or a business advantage.
  • Donations: does the company make charitable donations and up to what amount?
  • Record-keeping: the company must keep financial records and provide evidence as to the business reason for making or receiving payments.
  • Your responsibilities: workers have a duty to comply with this policy and must notify the compliance officer of any concerns or suspicions of a bribery offence.
  • How to raise a concern: concerns should be raised to the compliance officer in accordance to the company's internal procedures or whistleblowing policy if applicable.
  • Protection: the company should encourage openness and support anyone who raises genuine concerns in good faith under this policy.
  • Training and communication: how and when is this policy communicated to employees, suppliers, contractors, business partners, actual and potential clients.
  • Breaches of this policy: any employee who breaches the anti-bribery policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
  • Potential risk scenarios: "red flags": what are the red flag scenarios workers must be aware of?


How to create an anti-bribery policy?

Individuals working for your company as employees or workers must read, understand and sign your company's policy in order to prevent bribery and corruption. To create an anti-corruption and anti-bribery policy which is tailored to your company's needs simply register a Legislate account and select the agreement from the list of contracts. Moreover, you can create a company policy bundle to ensure your workers have access to other important documents such as anti-slavery policy and staff handbook.

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