Have you ever suspected acts of bribery or corruption in your business? These days you can never be too careful, and creating a comprehensive anti-bribery and corruption policy is not just good practice; it’s essential for maintaining trust, reputation, and legal compliance.

In today’s article, we’ll take a look at the key components of an anti-bribery and corruption policy, outlining why it’s imperative for your organisation, with tips on what to include in your ABC policy under the Bribery Act of 2010.

Business partnership meeting in office

What is bribery?

Bribery is a form of corruption that involves offering, giving, receiving, or soliciting anything of value to influence the actions of an individual (associated person) or business, especially in positions of power or authority.

Examples of bribery include offering monetary payments, gifts, favours, loans, or other benefits to secure preferential treatment, contracts, or decisions. It also involves non-monetary inducements like job offers, promotions, or personal gain opportunities.

Bribery can occur in various forms and contexts, from subtle gestures of goodwill to blatant attempts at manipulation. Regardless of its guise, the impact of bribery is far-reaching, which is why proactive anti-bribery and corruption measures are important.

Overview of the Bribery Act 2010

The Bribery Act 2010 is an important piece of legislation aimed at combating bribery and corruption in the UK or overseas. It establishes stringent penalties for associated persons (e.g. employees, agents, contractors, or subsidiaries) and organisations engaging in bribery, whether in the public or private sector.

The Bribery Act 2010 cover four key offences:

  • Bribing Another Person
  • Requesting, Agreeing to Receive, or Accepting a Bribe
  • Bribery of Foreign Public Officials
  • Failure to Prevent Bribery

Understanding its principles is crucial for developing an effective anti-bribery and corruption strategy. Read our latest blog on what your business needs to know about the Bribery Act 2010 for more information.

What is an anti-bribery and corruption policy?

An anti-bribery and corruption policy is a set of guidelines and procedures designed to prevent, detect, and address instances of bribery and corruption within a business. It serves as a framework to promote ethical conduct and mitigate risks that may result in disciplinary actions or criminal convictions. By setting clear expectations for employees and stakeholders on the issues of bribery and corruption, the policy helps protect businesses against potential legal consequences of non-compliance.

Is an anti-bribery and corruption policy a legal requirement?

While it is not a legal requirement, having an anti-bribery and corruption policy in place is strongly encouraged, no matter the size or nature of your business. Many regulatory bodies and industry standards necessitate such policies for HR or Health & Safety compliance. Therefore, implementing an effective ABC policy, supported by appropriate procedures and controls, can help defend your business against allegations of failure to prevent bribery.

What to include in your anti-bribery and corruption policy

Various factors should be taken into account concerning anti-bribery and corruption measures for your business. The level of defence against bribery depends on the extent of risk involved, and your anti-bribery and corruption policy should be tailored accordingly to reflect this.

Here are crucial elements to include in your anti-bribery and corruption policy:

Clear definitions

Define what constitutes bribery and corruption within your business, including examples of prohibited conduct.

Management commitment

Demonstrate visible commitment from top management to uphold ethical standards and enforce the policy.

The purpose of the policy

Clearly outline the objectives and goals of the anti-bribery and corruption policy, including adherence to relevant laws, ethical standards, and meditating risks.


Risk assessment

Assessing vulnerabilities in business operations, identifying high-risk areas, and implementing appropriate controls to mitigate these risks.

Gift, hospitality, or donation guidelines

Provide guidelines and restrictions on giving and receiving gifts, hospitality, or donations to and from external parties.

Strategies to reduce and manage bribery and corruption risks

Outline proactive measures and strategies to prevent, detect, and respond to instances of bribery and corruption, from conducting due diligence to establishing a culture of integrity.

Procedures for whistleblowing

Establish confidential channels and procedures for employees and stakeholders to report suspected instances of bribery or corruption without fear of retaliation.

Information on reporting bribes

Provide clear instructions on how employees should report any attempts or instances of bribery or corruption, both internally and externally to relevant authorities.


Offer regular training and awareness programs on anti-bribery and corruption policies, procedures, and legal requirements.

Reviewing and updating the policy

Monitor compliance with the ABC policy and update it in response to changing circumstances, emerging risks, or legal requirements.

Get compliance assistance from Smas

At Smas Worksafe, we understand the complexities of navigating anti-bribery and corruption regulations. Our team of experts specialises in developing tailored PQQ packages to help organisations mitigate risks and ensure compliance.

Contact us today by calling 01752 643962 or request a quote to learn more about our services and enhance your current SSIP accreditation. Plus, access our pre-qualification questionnaire template for contractors using our supply chain management service to effectively oversee your contractors and maintain strong supplier relationships.