Written with our partners at:
What's a bribery policy and when do you need it?
You should have an anti-bribery policy in place for your employees and workers. This policy is drafted to apply to all your employees, contractors, consultants, officers, interns, casual and agency workers, and anyone else under their or your control, who must comply with this policy, in line with legal requirements.
The template sets out both their and your duties and commitment to meet the appropriately high standards of operational integrity and legal compliance that you must set. It also contains guidance on how to identify instances of bribery and corruption and what steps to take if you discover that it is taking place.
Engaging in, supporting or failing to prevent bribery and corruption is almost always a criminal offence under UK law. Bribery is a bribe – which may manifest in multiple ways. It could be a reward, or maybe an inducement for acting improperly, illegally, or unethically to gain an advantage – whether personal, commercial, or regulatory.
That incentive or inducement can be less obvious than something that is actually given to you. And you don’t need to have actually given or received that reward or inducement for this process to amount to bribery and therefore unlawful conduct.
Our experts recommend that you do not give this policy contractual status in any employment or other contract that you put in place, but that you do reference it in that contract, make clear that the employee is expected to comply with the policy and that you have the right to update or revise it, in your discretion and when you want to.
This template includes all the statutory requirements, as well as optional elements for you to consider.