Anti-Bribery Policy Template for UK Businesses
An anti-bribery policy is a written document that sets out your organisation's zero-tolerance position on bribery and corruption. Under section 7 of the Bribery Act 2010, UK businesses face a strict liability corporate offence of failing to prevent bribery — and the only defence is proving you had 'adequate procedures' in place. A clear, comprehensive anti-bribery policy is the cornerstone of those adequate procedures, as outlined in the Ministry of Justice's six principles guidance.
Who Needs This Policy?
Every UK business should have an anti-bribery policy, regardless of size. The Bribery Act 2010 applies to all commercial organisations with a connection to the UK, including sole traders, partnerships, and limited companies. Businesses operating internationally, dealing with government contracts, or using agents and intermediaries face higher risk and should treat this policy as essential. The Serious Fraud Office has prosecuted SMEs as well as large corporates.
What's Covered
This anti-bribery policy template covers 14 key sections:
Purpose
This policy sets out the responsibility of [your details] and all its employees, workers, and associated persons to obse...
Scope
This policy applies to all individuals working at all levels and grades of [your details], including: - Employees (perma...
Policy Statement
[your details] has a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairl...
What is Bribery
A bribe is a financial or other advantage offered, promised, given, requested, or received to induce or reward a person ...
Gifts and Hospitality
[your details] recognises that the giving and receiving of gifts and hospitality is a normal part of business relationsh...
Political and Charitable Donations
[your details] does not make political donations or contributions to political parties, candidates, or campaigns. Chari...
Due Diligence on Third Parties
[your details] will carry out proportionate due diligence on third parties who act on our behalf or with whom we have si...
Record Keeping
[your details] will maintain accurate and complete records of all financial transactions and business dealings. This is ...
Reporting Concerns
All employees and associated persons are encouraged to raise concerns about any suspicion of bribery or corruption as so...
Consequences of Non-Compliance
Any employee who breaches this policy will face disciplinary action, which may include summary dismissal for gross misco...
Training
[your details] will provide anti-bribery training to all employees as part of their induction. Refresher training will b...
Roles and Responsibilities
is responsible for: - Setting the tone from the top and demonstrating commitment to anti-bribery (Principle 1: Top-leve...
Related Policies
This policy should be read alongside the following policies: - Whistleblowing Policy - Data Protection Policy - Discipl...
Review
This policy will be reviewed annually, or sooner if there are changes to the Bribery Act, Ministry of Justice guidance, ...
Legal Framework
This policy template is grounded in the following UK legislation and guidance:
How Complaiance Helps
Our anti-bribery policy goes beyond a generic template:
- Pre-built sections covering all six Ministry of Justice principles for adequate procedures
- Customisable gift and hospitality thresholds tailored to your business size and industry
- Automatic inclusion of reporting channels and whistleblowing cross-references
- Plain-English drafting that your employees will actually read and understand
Generate Your Anti-Bribery Policy Now
Answer a few questions about your business and get a customised, legally compliant anti-bribery policy in minutes.
Get Started FreeFrequently Asked Questions
Is an anti-bribery policy a legal requirement in the UK?
While there is no standalone legal requirement to have a written anti-bribery policy, section 7 of the Bribery Act 2010 creates a corporate offence of failing to prevent bribery. The only defence is demonstrating 'adequate procedures' — and the Ministry of Justice guidance lists having a proportionate anti-bribery policy as a core element. In practice, not having one leaves your business exposed to unlimited fines and criminal prosecution.
What should a UK anti-bribery policy include?
A compliant anti-bribery policy should cover: a clear zero-tolerance statement from senior leadership, the scope of who it applies to (employees, contractors, agents), definitions of bribery with practical examples, rules on gifts and hospitality with monetary thresholds, due diligence procedures for third parties, record-keeping requirements, reporting and whistleblowing channels, and consequences for breach including disciplinary action and criminal penalties under the Bribery Act 2010.
What are the penalties for bribery under UK law?
Under the Bribery Act 2010, individuals convicted of bribery offences face up to 10 years' imprisonment and an unlimited fine. Organisations convicted of failing to prevent bribery face an unlimited fine. Directors can also be personally liable under section 14 if the offence was committed with their consent or connivance. A conviction also triggers debarment from public contracts.