UK Anti-Bribery & Corruption Policy Template

What is a UK anti-bribery & corruption policy?

Quick answer. A UK anti-bribery & corruption policy is the written commitment to prevent bribery and the documented procedures backing it up. Required as the first of the six MoJ "adequate procedures" principles under the Bribery Act 2010 section 7, which gives a complete statutory defence to commercial organisations that had adequate procedures in place when an associated person committed bribery on the organisation's behalf.

The policy operates as the constitutional anchor for the rest of the anti-bribery programme. Without it, the other five MoJ "adequate procedures" principles (proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, monitoring and review) have nowhere to attach. Critically, the policy must address all four Bribery Act offences: section 1 (paying a bribe), section 2 (receiving a bribe), section 6 (bribing a foreign public official), and section 7 (failure of a commercial organisation to prevent bribery). The section 7 offence is the one that most concerns commercial organisations because it creates strict liability for the acts of associated persons (employees, contractors, subsidiaries, agents) — the only defence is showing adequate procedures, and the policy is the documentary core of that defence.

Who needs a UK anti-bribery & corruption policy?

Quick answer. Every UK commercial organisation, regardless of size or sector. The Bribery Act applies to UK-incorporated entities globally and to non-UK organisations carrying on business in the UK. Particularly critical for: anyone with international operations, supplier relationships in higher-risk jurisdictions, public-sector contracts, FCA-regulated firms, charities (Charity Commission expectations), and listed entities (US FCPA exposure for US-listed UK firms).

The Bribery Act is one of the most extra-territorial pieces of UK criminal law. A UK-incorporated company can be prosecuted in England for bribery committed by its overseas subsidiary acting through associated persons in any country. The penalties are uncapped (unlimited fines for organisations, up to 10 years imprisonment for individuals). The Serious Fraud Office continues to bring section 7 cases, with several deferred prosecution agreements in 2023–24 imposing fines in the tens of millions. The policy is the foundational evidence for the section 7 statutory defence — without it, the defence collapses. FCA-regulated firms face additional sector-specific anti-bribery expectations under SYSC 6 and FCPP. Public-sector suppliers face explicit anti-bribery clauses in Crown Commercial Service contracts. US-listed UK firms face overlapping FCPA exposure that the policy must also address.

What must a UK anti-bribery & corruption policy include?

Quick answer. Eight clauses anchored in the MoJ's six adequate-procedures principles: zero-tolerance statement signed by the CEO/Board, scope (employees, contractors, agents, JV partners, subsidiaries), the four Bribery Act offences defined, gifts and hospitality rules with monetary thresholds, facilitation payments prohibition, due diligence on third parties, training and acknowledgement requirements, and reporting routes for suspected bribery (cross-reference to whistleblowing).

• Zero-tolerance statement signed by CEO or Board (top-level commitment, MoJ Principle 2) — description with citation.
• Scope — employees, contractors, agents, joint-venture partners, subsidiaries, and any other associated persons under Bribery Act 2010 s8 — description with citation.
• The four Bribery Act offences defined (paying, receiving, bribing foreign officials, corporate failure to prevent) — description with citation.
• Gifts and hospitality rules with named monetary thresholds (typical UK SME: £100 receive, £200 give, escalation above), gift register requirement — description with citation.
• Facilitation payments prohibition (no exception for "small payments to grease the wheels" — Bribery Act has no de minimis) — description with citation.
• Due diligence on third parties — suppliers, agents, JV partners, M&A targets (MoJ Principle 4) — description with citation.
• Training and acknowledgement — annual mandatory, retained evidence (MoJ Principle 5) — description with citation.
• Reporting routes for suspected bribery (named recipient, anonymous channel, cross-reference whistleblowing policy) — description with citation.

How does this map to UK compliance regulation?

Quick answer. The policy is the foundation of the section 7 statutory defence under the Bribery Act 2010, mapped to the six MoJ "adequate procedures" principles. Sector overlays: FCA SYSC 6 for financial services, SFO Corporate Co-operation Guidance, and US FCPA for cross-listed organisations.

The Serious Fraud Office investigates section 7 corporate offences under deferred prosecution agreement framework. The SFO's 2023 Corporate Co-operation Guidance makes clear that organisations with documented anti-bribery programmes — policy + risk assessment + training + due diligence + monitoring — receive substantially more favourable treatment than those without. Tribunals and the SFO examine all six MoJ principles together; missing any one undermines the section 7 defence. The policy must also align with the whistleblowing policy for reporting routes, and with the disciplinary policy for handling internal bribery findings.

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