Anti-Bribery Policy UK: Bribery Act 2010 Guide

Overview

An Anti-Bribery and Corruption Policy is an internal document that sets out how a business, and the people who work for it, are expected to behave when it comes to gifts, payments, hospitality and dealings with third parties. It is not a piece of legislation in itself.

Rather, it is the practical way an employer translates the legal duties under the Bribery Act 2010 into rules that staff, contractors, agents and other associated persons can actually follow. A good policy will explain what bribery means in plain English, cover facilitation payments, set out the position on corporate hospitality, describe how concerns should be raised internally, and make clear what happens if the rules are broken.

For most UK businesses the policy sits alongside other compliance documents such as a whistleblowing policy, a gifts and hospitality register and a code of conduct. Taken together, these materials form part of what the Act refers to as 'adequate procedures', which is central to how a company defends itself if something goes wrong.

Key steps

1. Assess your bribery risk. Start by looking honestly at where corruption risks could arise in your business. Think about the sectors you operate in, the countries you trade with, whether you use agents or intermediaries, and whether public officials are ever involved in your supply chain or sales process. A documented risk assessment is the foundation for everything that follows.
2. Draft a written policy that fits your business. A policy copied from the internet rarely works well. The document should reflect your size, your industry and the real risks identified in your assessment. Cover gifts and hospitality, charitable and political donations, facilitation payments, third-party due diligence, and the consequences of breaching the rules. Keep the language practical so staff can actually use it.
3. Communicate the policy and train your people. A policy sitting on a shared drive will not help you if something goes wrong. Roll the document out to every employee, explain why it matters and provide training that is proportionate to each role. Higher-risk roles such as sales, procurement and finance usually need more detailed sessions, with refresher training at sensible intervals.
4. Put reporting and monitoring in place. Staff need a clear, safe way to raise concerns without fear of retaliation, which links closely to your whistleblowing arrangements. Keep a gifts and hospitality register, review it regularly, and make sure senior management has visibility of anything unusual. Document decisions so you can show what was done and why.
5. Review and refresh the policy regularly. Business changes, the law develops and risks shift over time. Set a regular review date, ideally at least annually, and update the policy after any significant event such as entering a new market, acquiring a business, or a near-miss report. Keep records of each review so you can demonstrate continuous improvement.

Common questions