Anti-Bribery and Corruption Policy Template in the UK

If you’re running a small business in the UK, you’re expected to guard against bribery and corruption - not just in your own team, but right through your supply chain. The good news? With the right policy, training and controls, you can meet your legal duties and protect your business from day one.

In this guide, we’ll walk you through what the UK Bribery Act 2010 requires, what to include in an anti-bribery and corruption policy, and provide a practical template outline you can adapt. We’ll also cover implementation steps, common pitfalls, and how to keep your policy effective as you grow.

What Does UK Law Require On Bribery And Corruption?

The Bribery Act 2010 is one of the toughest anti-bribery laws in the world. It creates several offences, including:

• Offering or giving a bribe
• Requesting or receiving a bribe
• Bribery of a foreign public official
• The “failure to prevent bribery” offence for organisations (Section 7)

That last offence is the one that catches a lot of businesses out. A company can be criminally liable if a person associated with it (like an employee, agent or supplier) bribes another person intending to obtain or retain business for the company. The only defence is to show your business had “adequate procedures” designed to prevent bribery.

The Ministry of Justice (MoJ) guidance breaks “adequate procedures” into six principles:

• Proportionate procedures
• Top-level commitment
• Risk assessment
• Due diligence
• Communication (including training)
• Monitoring and review

Your anti-bribery and corruption policy is the backbone of those procedures. It sets your standards, assigns responsibilities and explains how to handle risk. Just as importantly, it signals to staff and third parties that you take compliance seriously.

What Should An Anti-Bribery And Corruption Policy Include?

A good policy should be clear, practical and tailored to your risk profile. For most SMEs, these are the key elements to include:

1) Purpose, Scope And Definitions

• State that your business prohibits bribery and corruption in all forms and will comply with the Bribery Act 2010.
• Define “bribe”, “facilitation payment”, “kickback”, “public official”, “third party” and “associated person” in plain English.
• Confirm the policy applies to all employees, officers, contractors, agency workers, and relevant third parties acting on your behalf.

2) Zero-Tolerance Commitment And Responsibilities

• Set a zero-tolerance stance on offering, giving, requesting or accepting bribes.
• Assign responsibilities at board/owner level (top-level commitment) and day-to-day compliance leads (e.g., Finance/Operations).
• Link the policy to disciplinary procedures and contractual consequences, including potential dismissal for gross misconduct.

3) Gifts, Hospitality And Expenses

• Allow reasonable, proportionate, and transparent hospitality that supports legitimate business relationships.
• Prohibit cash gifts and anything that could improperly influence a decision.
• Set thresholds and pre-approval rules (e.g., gifts over £50 require manager approval; hospitality over £200 requires director sign-off).
• Require timely recording in a Gifts & Hospitality Register and clear expense documentation.

4) Facilitation Payments And Political/Charitable Contributions

• Ban facilitation payments (small unofficial payments to speed up routine actions) - they’re illegal under UK law.
• Set out a process for charitable donations and sponsorships (transparent, approved, recorded).
• Restrict political donations unless approved at top level and recorded.

5) Third Parties, Agents And Suppliers

• Set due diligence requirements for higher-risk third parties (e.g., agents paid on commission, sales intermediaries, overseas distributors).
• Require written contracts with anti-bribery warranties, audit rights and termination for breach. This is often built into your Supply Agreement or other commercial contracts.
• Set onboarding checks (company ownership, reputation checks, sanctions list checks where relevant) proportionate to risk.

6) Conflicts Of Interest

• Require staff to declare personal interests that could influence (or appear to influence) business decisions.
• Keep a conflicts register and set escalation procedures. Many SMEs support this with a separate Conflict of Interest Policy.

7) Reporting, Whistleblowing And Investigations

• Provide clear reporting channels for concerns (line manager, compliance lead, anonymous reporting option).
• Guarantee no retaliation for good-faith reports. Many businesses pair this with a dedicated Whistleblower Policy.
• Outline how allegations will be assessed, investigated and resolved. Where staff are involved, have a fair process aligned with your disciplinary rules and, if needed, formal workplace investigations.

8) Training, Communication And Record-Keeping

• Set induction training for new starters and refreshers for higher-risk roles (sales, procurement, overseas teams).
• Keep training records, approvals and registers (gifts/hospitality, conflicts, due diligence).
• Explain how and where you’ll store records, and retention timelines proportionate to risk.

9) Monitoring, Review And Continuous Improvement

• Commit to an annual (or risk-based) review by the leadership team.
• Track KPIs: number of gifts/hospitality entries, training completion, third-party due diligence completion, incidents raised.
• Update procedures following incidents, audits, legal changes or expansion into new markets.

10) Consequences Of Breach

• Explain that breaches may lead to disciplinary action up to dismissal, contract termination for third parties, and reporting to authorities where appropriate.
• Cross-reference relevant documents such as your Employment Contract and Staff Handbook so expectations are consistent across policies.

Anti-Bribery And Corruption Policy Template Outline You Can Adapt

Use the structure below to draft your policy. Keep it short, clear and tailored to your business. Avoid copying a generic template without adapting thresholds, approvals and risk controls - your procedures must be “proportionate” to your actual risks.

1) Policy Statement

has a zero-tolerance approach to bribery and corruption. We comply with the UK Bribery Act 2010 and require all employees and third parties acting on our behalf to do the same. We will take disciplinary and contractual action where this policy is breached.

2) Scope And Definitions

This policy applies to all employees, officers, contractors, agency workers, intermediaries, suppliers and any other “associated persons”. A bribe is any financial or other advantage offered, given, requested or received to induce or reward improper performance.

3) Prohibited Conduct

• Offering, giving, requesting or accepting bribes
• Making facilitation payments
• Improperly influencing public officials
• Authorising, assisting or ignoring bribery by third parties

4) Gifts, Hospitality And Expenses

• Reasonable hospitality is permitted where proportionate and transparent.
• No cash gifts or equivalent (e.g., vouchers) allowed.
• Approvals: gifts over £ → manager approval; hospitality over £ → director approval.
• Record all hospitality and gifts in the Gifts & Hospitality Register within days.

5) Charitable And Political Contributions

• Charitable donations require approval and must be recorded.
• No political donations unless approved by the board/owners and recorded.

6) Third Parties And Due Diligence

• Conduct proportionate due diligence for higher-risk third parties (e.g., commission-based agents).
• Contracts with third parties must include anti-bribery clauses, audit rights, and termination for breach.

7) Conflicts Of Interest

• Declare any actual or potential conflicts using the Conflicts Register.
• Escalate to for mitigation measures (e.g., recusal from decisions).

8) Reporting And Whistleblowing

• Report concerns to or via our anonymous channel.
• No retaliation against anyone who raises a concern in good faith.

9) Training And Communication

• All employees complete induction training; high-risk roles complete annual refresher training.
• Records of training and acknowledgements are retained by .

10) Monitoring And Review

• The leadership team will review this policy annually or sooner if risks change.

11) Breach And Consequences

• Disciplinary action up to summary dismissal for employees.
• Termination of contracts and possible reporting to authorities for third parties.

12) Roles And Contacts

• Policy owner:
• Compliance contact:
• Anonymous reporting:

How To Implement Your Anti-Bribery Policy In Practice

Having a policy is only half the story. You’ll need to embed it into everyday decision-making. Here’s a simple, practical rollout plan you can follow:

Step 1: Map Your Risks

Start with a short risk assessment. Consider:

• Where you operate (UK only vs. overseas markets, especially higher-risk jurisdictions)
• Who sells for you (employees vs. third-party agents or distributors)
• Procurement and tendering (are you dealing with public bodies?)
• Cash-intensive processes or large, discretionary discounts
• High-value gifts or entertainment in your sector

Write this down - even one page is fine for a small business. The point is to show your procedures are proportionate to your risks.

Step 2: Finalise The Policy And Align Your Documents

Tailor your thresholds, approvals and reporting lines. Then, update related documents so everything tells the same story:

• Include a conduct clause in each Employment Contract referencing anti-bribery rules and disciplinary action.
• Update your Staff Handbook so gifts/hospitality, conflicts and whistleblowing procedures match the policy.
• Embed anti-bribery warranties and termination rights in your commercial contracts such as your Supply Agreement and reseller or agency agreements.
• Where relevant, maintain a standalone Whistleblower Policy and a clear reporting email or hotline.

If you don’t have a central policy library yet, consider implementing a standardised Workplace Policy framework so staff always know where to find the latest version.

Step 3: Set Up Registers And Approval Flows

Keep it simple and sustainable. For example:

• A shared Gifts & Hospitality Register (spreadsheet or HR system) with date, recipient, value, purpose, and approver.
• A Conflicts Register noting the interest and mitigation steps.
• A supplier due diligence checklist saved with the signed contract.
• Expense approval workflows that flag gifts or hospitality above your thresholds.

Step 4: Train Your Team

At minimum, cover:

• What counts as a bribe (with realistic examples in your sector)
• How to handle gifts and hospitality requests
• Using the registers and getting approvals
• How to report concerns (and reassurance about anti-retaliation)

New starters should get this training in their first month, and anyone in a higher-risk role (e.g., sales or procurement) should complete an annual refresher.

Step 5: Investigate And Respond Consistently

When concerns arise, follow a consistent playbook. Acknowledge receipt, triage the risk, gather facts fairly, and document the outcome. If staff conduct is in question, align with your disciplinary procedures and, where necessary, conduct formal workplace investigations.

Step 6: Review Annually (Or When Risks Change)

Each year, revisit your risk assessment. Ask: did we expand to a new market? Engage more third-party sales agents? Increase average deal size? If yes, it might be time to tighten approvals, raise training frequency, or enhance due diligence.

Common Anti-Bribery Pitfalls For SMEs (And How To Avoid Them)

Even well-meaning businesses trip up on the practicalities. Here’s what we see most often - and what you can do about it.

1) Generic Templates That Don’t Fit

“Adequate procedures” must be proportionate to your risks. If your policy is too vague (or unrealistically strict), staff won’t follow it. Tailor thresholds, approval roles and examples to your actual operations.

2) Forgetting Third Parties

Most bribery risk in SMEs sits with third parties - commission-based agents, overseas intermediaries, or local fixers. Build due diligence into your onboarding and embed clauses in your contracts, ideally when you put a new Supply Agreement or sales agreement in place.

3) No Records

When an issue arises, your registers, approvals and training logs are your best evidence that you had adequate procedures. Keep them simple so they’re actually used.

4) Inconsistent Disciplinary Outcomes

If similar breaches lead to different outcomes, trust erodes. Align conduct expectations across your Staff Handbook and contracts, and apply your process consistently. Where conduct is serious, it may amount to gross misconduct.

5) Training That Doesn’t Stick

Tick-box training rarely changes behaviour. Use realistic scenarios from your sales cycle or supplier negotiations. Short, frequent refreshers beat a long annual course.

FAQs: Quick Answers For Busy Owners

Is Hospitality Ever Allowed Under The Bribery Act?

Yes, reasonable and proportionate hospitality that supports legitimate business relationships is acceptable. The key is intent, transparency, and recording in your Gifts & Hospitality Register. Set sensible thresholds and require pre-approval for higher-value hospitality.

Are Facilitation Payments Illegal In The UK?

Yes. The Bribery Act does not allow “grease payments” to speed up routine governmental actions. Your policy should say they’re prohibited and explain how to handle requests safely (e.g., refuse, escalate, and record the incident).

Do We Need A Whistleblowing Channel?

While not every SME is legally required to have a formal whistleblowing system, it’s strongly recommended. It helps you detect issues early and demonstrates top-level commitment. Many small businesses adopt a simple, confidential mailbox and a short Whistleblower Policy.

How Often Should We Review The Policy?

At least annually, or sooner if your risk profile changes (new markets, more third-party agents, larger public tenders). Keep a short record of the review to show continuous improvement.

What If A Client Insists On A “Thank You Gift”?

Apply your thresholds and approvals. If accepting would look improper (e.g., during a tender), politely decline. If it’s within policy limits, record it. A clear policy gives your team a script for handling awkward situations.

Key Takeaways

• The UK Bribery Act 2010 creates a “failure to prevent bribery” offence - your best defence is having adequate procedures, starting with a clear, proportionate anti-bribery and corruption policy.
• Your policy should cover scope, definitions, zero tolerance, gifts and hospitality rules, third-party due diligence, conflicts of interest, reporting, training, record-keeping, monitoring and consequences of breach.
• Tailor thresholds and approvals to your risks, keep simple registers, and build clauses into contracts like your Supply Agreement so you can enforce standards with third parties.
• Roll out the policy with training, aligned documents (such as your Employment Contract and Staff Handbook), and a practical reporting channel supported by a Whistleblower Policy.
• Review your risks annually, log incidents and approvals, and apply disciplinary processes consistently - serious breaches may amount to gross misconduct.
• If you’re unsure how to tailor the policy or embed it into contracts and processes, getting tailored advice is a smart move - it’s far easier (and cheaper) to prevent problems than to fix them later.

If you’d like help drafting an anti-bribery and corruption policy, building it into your contracts and rolling it out across your business, you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.