Does my company need an anti-bribery policy under English law?

If your company is incorporated or conducts business in the United Kingdom, it is subject to the Bribery Act 2010, which is widely regarded as one of the strictest anti-bribery laws in the world. Under section 7 of the Act, a commercial organisation commits a criminal offence if a person associated with it — including employees, agents, subsidiaries, and anyone else performing services on its behalf — bribes another person intending to obtain or retain business or a business advantage for the organisation. The only complete defence is to prove that the organisation had adequate procedures in place designed to prevent such conduct. The Ministry of Justice published guidance in 2011 (available on GOV.UK) setting out six principles for adequate procedures. A written anti-bribery and corruption policy is an essential component of those adequate procedures and demonstrates top-level commitment, which is Principle 2. Even small and medium-sized enterprises are at risk if they use agents or intermediaries, operate in higher-risk sectors, or export goods and services internationally. The Serious Fraud Office has made clear that it expects all UK commercial organisations to have appropriate controls in place.

What is the difference between section 1 and section 7 of the Bribery Act 2010?

The Bribery Act 2010 creates several distinct offences. Section 1 makes it an offence for an individual to offer, promise, or give a financial or other advantage to another person intending to induce them to perform a relevant function or activity improperly. Section 2 makes it an offence to request, agree to receive, or accept such an advantage. Section 6 targets bribery of foreign public officials specifically, and is drafted broadly to capture payments made through intermediaries. Section 7 is the corporate offence: it makes a commercial organisation criminally liable if a person associated with it (within the meaning of section 8) commits a section 1 or section 6 offence intending to obtain or retain a business advantage for the organisation. Unlike sections 1, 2, and 6, section 7 does not require proof of individual fault at senior management level — it is a strict liability offence, subject only to the adequate procedures defence. The maximum penalty for an organisation convicted under section 7 is an unlimited fine, and conviction may also lead to debarment from public procurement. Individuals convicted under sections 1, 2, or 6 face up to ten years' imprisonment and an unlimited fine.

What gifts and hospitality are permitted under the Bribery Act 2010?

The Bribery Act 2010 does not prohibit all corporate hospitality and gifts. Section 1 only creates an offence where a financial or other advantage is offered, promised, or given with intent to induce improper performance of a relevant function. Proportionate, transparent, and reasonable business entertainment is therefore lawful where it is not intended to influence a business decision improperly and is properly recorded. The Ministry of Justice Guidance explicitly states that the government does not intend for the Act to prohibit reasonable and proportionate hospitality and similar business expenditure that seeks to improve the image of a commercial organisation, better to present its products and services, or to establish cordial relations. The key factors are: whether the hospitality or gift is reasonable and proportionate in the context of the business relationship; whether it is transparent and recorded; whether it is offered at a time that could create a perception of influence (such as during a tender process); and whether it is given to a public official or a private sector employee. A clear policy with an appropriate threshold (such as £50 for gifts) helps to distinguish lawful hospitality from bribery.

Can my company be prosecuted for bribery by a third party acting on its behalf?

Yes. This is precisely the risk addressed by section 7 of the Bribery Act 2010. Under section 8, a person is associated with a commercial organisation if they perform services for or on behalf of the organisation, regardless of the legal nature of the relationship. This includes employees, but also agents, distributors, joint venture partners, subsidiaries, contractors, and any other intermediary acting in the organisation's name or on its behalf. If any such person bribes another person intending to obtain or retain business for the organisation, the organisation itself commits an offence. The organisation does not need to have known about or consented to the bribery — the offence is one of strict liability. The only defence is to demonstrate adequate procedures. This makes it essential for organisations to conduct anti-bribery due diligence on third parties, include anti-bribery obligations in their contracts, and monitor compliance. The Serious Fraud Office has prosecuted cases where UK companies were held responsible for conduct by overseas agents of which senior management claimed ignorance.

Are facilitation payments legal in the UK?

No. Unlike the United States Foreign Corrupt Practices Act 1977, which contains a limited exception for facilitation payments (also known as grease payments or speed money) made to foreign officials to expedite routine governmental actions, the Bribery Act 2010 contains no such exception. Facilitation payments are illegal under section 1 of the Act regardless of their size, the country in which they are made, or local custom or practice. The Ministry of Justice Guidance makes clear that the government recognised that a facilitation payments exception would have been inconsistent with the UK's international obligations under the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Organisations should train employees on how to handle demands for facilitation payments — which may include politely declining, seeking assistance from the relevant embassy or High Commission, or withdrawing from the transaction — and should have clear escalation procedures for reporting such demands. In practice, if an employee or agent makes a facilitation payment under genuine duress (for example, to avoid a credible threat of physical harm), this may be relevant to whether a prosecution is in the public interest, but it does not provide a legal defence.

What does the Ministry of Justice Guidance say about adequate procedures?

The Ministry of Justice published guidance under section 9 of the Bribery Act 2010 in March 2011, setting out six principles that collectively constitute the framework for adequate procedures. Principle 1 (Proportionate procedures) requires that an organisation's procedures to prevent bribery by associated persons are proportionate to the bribery risks it faces and the nature, scale, and complexity of its activities. Principle 2 (Top-level commitment) requires that the top-level management of a commercial organisation (whether a board of directors, the owners, or any other equivalent body or person) be committed to preventing bribery by persons associated with it and foster a culture in which bribery is never acceptable. Principle 3 (Risk assessment) requires that the organisation assess the nature and extent of its exposure to potential external and internal risks of bribery. Principle 4 (Due diligence) requires that the organisation apply due diligence procedures in respect of persons who perform or will perform services for or on behalf of the organisation. Principle 5 (Communication including training) requires that the organisation seek to confirm that its bribery prevention policies and procedures are embedded and understood throughout the organisation. Principle 6 (Monitoring and review) requires that the organisation monitor and review procedures and make improvements where necessary. The guidance is not prescriptive — the six principles are intended to be applied in a way that is proportionate to the specific risks faced by each organisation.

Anti-Bribery and Corruption Policy (England & Wales)

Anti-Bribery and Corruption Policy

Bribery Act 2010 — Adequate Procedures Defence

[Company Name]

Company Registration No. [Company Reg No.]

[Company Street], [Company City], [Company Postcode]

1. POLICY STATEMENT

[Company Name] (the "Company") is committed to conducting all of its business activities honestly, ethically, and with integrity. The Company has a zero-tolerance approach to bribery and corruption in any form, whether direct or indirect, active or passive, and in all countries in which the Company operates.

This Anti-Bribery and Corruption Policy (the "Policy") sets out the Company's responsibilities and the responsibilities of those working for or on behalf of the Company in relation to preventing bribery and corruption. It is intended to constitute "adequate procedures" under section 7(2) of the Bribery Act 2010 and the Ministry of Justice Guidance on adequate procedures published pursuant to section 9 of that Act.

This Policy has been approved by [Approved By] on [Approval Date] and takes effect on [Policy Date]. It is owned by [Policy Owner] and is sponsored by [Senior Officer Name], [Senior Officer Title].

2. SCOPE

This Policy applies to all individuals working at all levels and grades, including directors, officers, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with the Company, or any of its subsidiaries or their employees, wherever they are located (collectively referred to as "Associated Persons" in this Policy).

Third parties acting on behalf of the Company, including agents, distributors, intermediaries, joint venture partners, and supply chain participants, are required to comply with this Policy or equivalent standards under the terms of their contractual arrangements with the Company. Under section 8 of the Bribery Act 2010, a person associated with the Company includes any person who performs services for or on behalf of the Company, regardless of the legal form of the arrangement.

3. LEGAL FRAMEWORK

The primary legislation governing bribery and corruption in England and Wales is the Bribery Act 2010 (the "Act"). The Act came into force on 1 July 2011 and created a number of offences, including the offence under section 7 whereby a commercial organisation is guilty of failing to prevent bribery if a person associated with it bribes another person intending to obtain or retain business or a business advantage for the organisation.

The only defence available to an organisation charged under section 7 is to demonstrate that it had in place "adequate procedures" designed to prevent persons associated with it from undertaking such conduct. The Ministry of Justice published guidance in 2011 setting out six principles for adequate procedures: proportionate procedures; top-level commitment; risk assessment; due diligence; communication (including training); and monitoring and review.

Related legislation includes: the Proceeds of Crime Act 2002 (which creates offences in relation to the proceeds of bribery); the Serious Crime Act 2007 (which creates offences of encouraging or assisting crime); the Companies Act 2006 section 172 (directors' duty to act in the way most likely to promote the success of the company); and the Financial Services and Markets Act 2000 (where applicable to regulated entities).

4. WHAT IS BRIBERY?

A bribe is a financial or other advantage offered, promised, given, requested, agreed to receive, or accepted in order to induce a person to perform a relevant function or activity improperly, or to reward a person for doing so. Bribery does not require money to change hands — it includes gifts, hospitality, entertainment, loans, favours, kickbacks, donations, and any other benefit.

Corruption is the misuse of entrusted power for private gain and encompasses bribery as well as fraud, embezzlement, nepotism, and conflicts of interest.

The following are examples of conduct that would constitute bribery under the Bribery Act 2010:

offering a gift to a government official to expedite a permit or licence application;
accepting a commission or kickback from a supplier in return for directing business to that supplier;
making a payment to a third party in the knowledge that it will be passed on as a bribe;
offering excessive entertainment to a prospective client with the intention of influencing a commercial decision;
accepting disproportionate hospitality from a supplier who is seeking a contract renewal.

5. OFFENCES UNDER THE BRIBERY ACT 2010

The Bribery Act 2010 creates four principal offences:

Section 1 — Offences of bribing another person: it is an offence to offer, promise, or give a financial or other advantage to another person intending to induce them to perform a relevant function improperly, or knowing or believing that acceptance of the advantage would itself constitute improper performance.
Section 2 — Offences relating to being bribed: it is an offence to request, agree to receive, or accept a financial or other advantage intending that a relevant function should be performed improperly in consequence.
Section 6 — Bribery of foreign public officials: it is an offence to offer, promise, or give a financial or other advantage to a foreign public official intending to influence them in their capacity as a public official and to obtain or retain business or an advantage in the conduct of business.
Section 7 — Failure of commercial organisations to prevent bribery: a commercial organisation is guilty of this offence if a person associated with it bribes another person intending to obtain or retain business or a business advantage for the organisation, and the organisation cannot demonstrate that it had adequate procedures in place to prevent such conduct.

The penalties for offences under the Bribery Act 2010 include, for individuals, up to ten years' imprisonment and/or an unlimited fine. For organisations, the penalty is an unlimited fine. Conviction may also result in debarment from public contracts, confiscation of the proceeds of bribery under the Proceeds of Crime Act 2002, and serious reputational damage.

6. GIFTS AND HOSPITALITY

Normal and reasonable gifts and hospitality given or received in the ordinary course of business are permitted where they are proportionate, transparent, and in accordance with this Policy. However, gifts and hospitality must never be offered or accepted with the intention of influencing a business decision, obtaining a commercial advantage, or as a reward for improper conduct.

The following rules apply to all gifts and hospitality:

No gift with a value at or above [Gifts Threshold] may be offered or accepted without prior written approval from the compliance officer.
All gifts and hospitality offered or received at or above the threshold must be recorded in the Company's gifts and hospitality register within five working days.
Gifts of cash, cash equivalents (including gift cards and vouchers), or shareholdings must never be offered or accepted under any circumstances.
Gifts must not be offered during tender or procurement processes.
Entertainment that is lavish, disproportionate, or not connected to a legitimate business purpose is prohibited.
Gifts or hospitality must never be offered to or received from government officials or public sector employees without specific prior approval from the senior officer.

7. FACILITATION PAYMENTS

Facilitation payments — sometimes called "grease payments" or "speed money" — are unofficial payments made to government or public officials to secure or accelerate routine or mandatory actions to which the payer is legally entitled (such as the processing of permits, licences, customs clearance, or utility connections). Such payments are illegal under section 1 of the Bribery Act 2010 and are [Facilitation Payments Position].

The fact that facilitation payments are customary or expected in a particular country or sector does not make them lawful under English law, nor does it provide any defence to prosecution. Any request for a facilitation payment must be reported immediately to the compliance officer. Any Associated Person who makes or agrees to make a facilitation payment — even under duress — must report this to the compliance officer as soon as practicable.

8. POLITICAL AND CHARITABLE DONATIONS

Political donations: [Political Donations Position]. Any donation or contribution to a political party, politician, or political campaign could be perceived as an attempt to obtain an improper advantage and must be reviewed carefully for compliance with the Political Parties, Elections and Referendums Act 2000 and this Policy.

Charitable donations and sponsorships are permitted where they are made in good faith and not used as a mechanism to pay bribes or obtain business advantages. All charitable donations and sponsorships at or above [Charitable Donations Threshold] require prior written approval from the compliance officer. The compliance officer will assess whether the donation could be perceived as an attempt to influence a public official or obtain a business advantage.

9. RISK ASSESSMENT

The Company shall conduct and document a bribery risk assessment at intervals appropriate to its business activities and risk profile, and in any event no less frequently than every two years or following a material change in the Company's operations, markets, or structure. The risk assessment shall identify and evaluate the bribery risks facing the Company, having regard to the countries and sectors in which it operates, the nature of its business relationships, the value and volume of transactions, and the activities of associated persons.

The results of the risk assessment shall be reviewed by [Senior Officer Name], [Senior Officer Title], and used to inform proportionate updates to the procedures in this Policy and related controls.

10. RECORD KEEPING

The Company shall maintain accurate and complete records of all matters relevant to this Policy, including the gifts and hospitality register, third party due diligence records, training completion records, risk assessment reports, incident and investigation records, and approvals granted under this Policy. All such records must be retained for a minimum of [Record Keeping Period] from the date of the relevant transaction or event, in accordance with the Company's document retention schedule and the requirements of HMRC.

Accurate books and records are also required under the Companies Act 2006 section 386 and are essential to prevent the concealment of bribery within the Company's accounts. Any falsification, alteration, or destruction of records to conceal bribery is itself a criminal offence.

11. TRAINING AND COMMUNICATION

Anti-bribery training shall be provided to all employees [Training Frequency]. Training shall be tailored to the role and assessed bribery risk of each employee, with enhanced training for those in higher-risk functions (including sales, procurement, finance, and those operating in higher-risk jurisdictions). Training completion shall be recorded and the records retained in accordance with section 11.

This Policy shall be communicated to all employees on commencement of employment, at each training cycle, and whenever it is materially updated. It shall also be communicated to relevant third parties as part of the due diligence and contracting process. The Policy shall be made available on the Company's intranet and, where applicable, its external website.

12. REPORTING CONCERNS AND WHISTLEBLOWING

Any Associated Person who suspects that bribery or corruption has occurred, is occurring, or is about to occur — whether involving an employee, a third party, or any other person — must report their concern as soon as practicable to the compliance officer using the following contact: [Whistleblowing Contact].

Reports may be made anonymously where the reporting channel permits. The Company is committed to ensuring that no person suffers any detrimental treatment as a result of raising a concern in good faith under this Policy, even if that concern is ultimately not substantiated. Detrimental treatment includes dismissal, disciplinary action, threats, or any other form of retaliation. Such treatment will itself be treated as a disciplinary offence.

Protection for individuals who report suspected bribery in good faith is available under the Public Interest Disclosure Act 1998 (as amended by the Enterprise and Regulatory Reform Act 2013) where the disclosure is a qualifying disclosure made to an appropriate person. Associated Persons who raise concerns in good faith will receive protection from retaliation under this Policy regardless of whether the statutory tests are met.

13. INVESTIGATION PROCEDURES

All reports of suspected bribery or corruption shall be investigated promptly, thoroughly, and confidentially by the compliance officer (or, where the compliance officer is implicated, by a senior director or an independent external investigator appointed by the Board). The investigation shall be proportionate to the seriousness of the allegation and conducted in accordance with the principles of natural justice.

Where an investigation reveals credible evidence of bribery, the matter shall be escalated to the senior officer and, where appropriate, referred to the National Crime Agency (NCA) or other relevant authorities. The Company may make a Suspicious Activity Report (SAR) to the NCA under the Proceeds of Crime Act 2002 where bribery is suspected. The Company will cooperate fully with any investigation by the Serious Fraud Office, the NCA, the police, or any other competent authority.

14. SANCTIONS FOR BREACH

Any breach of this Policy by an employee or director will be treated as a serious disciplinary matter and may result in summary dismissal for gross misconduct without notice or payment in lieu of notice. Breach of this Policy may also constitute a criminal offence, and the Company reserves the right to report such breaches to the relevant authorities and to cooperate fully with any criminal investigation.

Third parties who breach their contractual obligations to comply with this Policy or equivalent standards may have their contracts terminated immediately. The Company may also seek to recover any losses suffered as a result of a breach of this Policy from the party responsible.

15. RESPONSIBILITIES

Senior leadership: [Senior Officer Name], [Senior Officer Title], has overall senior management responsibility for this Policy, its implementation, and the Company's compliance with the Bribery Act 2010. The Board of Directors is responsible for ensuring that the Company has adequate procedures in place as required by section 7(2) of the Act.

Compliance officer: [Compliance Officer Name] ([Compliance Officer Email]) is responsible for the day-to-day operation and administration of this Policy, including maintaining the gifts register, coordinating training, conducting due diligence reviews, investigating reports, and reporting to senior management on compliance matters.

All employees and associated persons are responsible for reading, understanding, and complying with this Policy, completing required training, and reporting any concerns or suspicions of bribery promptly.

16. REVIEW AND MONITORING

This Policy shall be reviewed by the compliance officer no less frequently than every two years, and following any material change in the law, regulatory guidance, the Company's business activities, or risk profile. The review shall assess whether the procedures remain proportionate, adequate, and effective. The results of the review shall be reported to the senior officer and, where appropriate, to the Board.

The Company shall monitor compliance with this Policy through periodic internal audits, management information, and reports from the compliance officer. Any material non-compliance identified during monitoring shall be escalated to the senior officer for action.

17. APPROVAL

This Anti-Bribery and Corruption Policy has been approved by [Approved By] on [Approval Date].

Policy Owner: [Policy Owner]

Effective Date: [Policy Date]

Senior Officer

[Senior Officer Name]

Signature

Date: ________________

Maintained by Vladislav Sergienko, Founder·Template last modified: 2026-06-23·Report an error

What Is a Anti-Bribery and Corruption Policy (England & Wales)?

An Anti-Bribery and Corruption Policy in the United Kingdom sets out the standards, responsibilities, and procedures the organisation expects everyone to follow, with its requirements set by the Bribery Act 2010.

The Bribery Act 2010, which came into force on 1 July 2011, is widely recognised as one of the most stringent anti-bribery statutes in the world. It creates a number of individual offences (sections 1, 2, and 6) as well as the corporate offence under section 7, which makes commercial organisations criminally liable for failing to prevent bribery by a person associated with them. Unlike the predecessor legislation under the Prevention of Corruption Acts 1889 to 1916, the Bribery Act applies to conduct occurring entirely outside the United Kingdom where the relevant commercial organisation was incorporated in, or carries on business from, the UK.

Section 7 is a strict liability offence: the prosecution does not need to prove that senior management knew about or consented to the bribery. The only defence available is for the organisation to demonstrate, on a balance of probabilities, that it had in place adequate procedures designed to prevent persons associated with it from undertaking such conduct. This makes an Anti-Bribery and Corruption Policy not merely good practice but a legal necessity for any commercial organisation subject to the Act.

The Ministry of Justice published guidance in March 2011, as required by section 9 of the Act, setting out six principles for adequate procedures: proportionate procedures; top-level commitment; risk assessment; due diligence; communication including training; and monitoring and review. A well-drafted Anti-Bribery and Corruption Policy addresses all six principles and is supported by supplementary procedures such as a gifts and hospitality register, a third party due diligence process, and a whistleblowing mechanism.

The Companies Act 2006 section 172 also requires directors to act in the way most likely to promote the success of the company. A bribery or corruption scandal can cause catastrophic reputational and financial harm, making strong anti-bribery controls a matter of good governance as well as legal compliance.

The legal framework governing the Anti-Bribery and Corruption Policy (England & Wales) in United Kingdom draws on several key statutes and regulatory bodies. Under the Companies Act 2006, Companies House maintains the register of UK companies. Section 386 of the Companies Act 2006 sets accounting record obligations. The Competition and Markets Authority (CMA) enforces the Consumer Rights Act 2015. The Financial Conduct Authority (FCA) regulates financial services under the Financial Services and Markets Act 2000. The High Court of Justice has jurisdiction under the Senior Courts Act 1981. Parties executing a Anti-Bribery and Corruption Policy (England & Wales) in United Kingdom should confirm the document reflects current law, including any amendments enacted since the original drafting date. The Bribery Act 2010 sets the foundational requirements.

When Do You Need a Anti-Bribery and Corruption Policy (England & Wales)?

An Anti-Bribery and Corruption Policy is required by any commercial organisation that carries on business in the United Kingdom or is incorporated in the United Kingdom, regardless of size or sector. The Bribery Act 2010 applies to limited companies, limited liability partnerships, sole traders, and partnerships that carry on business in the UK. There is no minimum turnover threshold or employee headcount below which the Act does not apply.

The policy is particularly important in the following circumstances. First, where the organisation uses agents, intermediaries, or distributors to access markets or win contracts — especially in sectors or countries where corruption risk is elevated. The Corruption Perceptions Index published annually by Transparency International identifies countries where bribery risk is high. The Serious Fraud Office has indicated that it scrutinises closely the controls applied to relationships with agents operating in high-risk jurisdictions.

Second, where the organisation operates in sectors with elevated bribery risk. These include construction and engineering, defence and aerospace, extractive industries (oil, gas, and mining), pharmaceuticals and healthcare, financial services (particularly where public sector entities are involved), and public procurement generally.

Third, where the organisation employs individuals who interact with government officials, public sector employees, or state-owned enterprises. Section 6 of the Bribery Act 2010 creates a specific offence of bribery of foreign public officials, and section 7 applies equally to conduct intended to influence such officials through associated persons.

Fourth, where the organisation is a supplier to the public sector. Many government contracting authorities require tenderers to demonstrate that they have adequate anti-bribery procedures in place as a condition of qualification. Conviction under the Bribery Act 2010 may result in mandatory debarment from public procurement under the Public Contracts Regulations 2015.

Fifth, where the organisation has international operations or is expanding into new markets. Bribery risk is not limited to developing economies — the Serious Fraud Office and the National Crime Agency both investigate domestic as well as international bribery. However, the risk is typically higher where employees or agents interact with foreign government officials.

Even where the assessed risk is low, having a written policy demonstrates top-level commitment (Ministry of Justice Guidance Principle 2) and is a prerequisite for all other adequate procedures. It is also expected by institutional investors, major customers, and supply chain partners, many of whom conduct anti-bribery due diligence on their counterparties as standard practice.

What to Include in Your Anti-Bribery and Corruption Policy (England & Wales)

A legally effective Anti-Bribery and Corruption Policy for England and Wales must address the six principles set out in the Ministry of Justice Guidance on adequate procedures under the Bribery Act 2010.

A clear policy statement sets out the organisation's zero-tolerance commitment to bribery and corruption and establishes the legal framework — the Bribery Act 2010, the Proceeds of Crime Act 2002, and related legislation. It should be signed or endorsed by the most senior individual in the organisation (the Chief Executive or equivalent) to satisfy the top-level commitment principle.

Scope and application confirms who the policy applies to, including not just employees and directors but also agents, consultants, contractors, joint venture partners, and supply chain participants who fall within the definition of associated persons under section 8 of the Act.

Definitions of bribery and corruption should be clear and include examples relevant to the organisation's business, such as gifts and hospitality, facilitation payments, kickbacks, and political or charitable donations used as cover for bribes.

Gifts and hospitality procedures should specify the threshold above which gifts must be reported and approved, the requirement to maintain a gifts and hospitality register, and the prohibition on gifts of cash or cash equivalents. A proportionate threshold (for example £50) is commonly adopted in practice, though the appropriate level will depend on the organisation's size and sector.

Facilitation payments must be expressly prohibited. Unlike US law, there is no facilitation payments exception under the Bribery Act 2010, and the policy must make this absolutely clear to employees and associated persons.

Third party due diligence procedures set out how the organisation assesses the bribery risk presented by agents, distributors, and other associated persons, and the contractual protections it requires (including anti-bribery representations and audit rights).

Whistleblowing and reporting mechanisms provide accessible channels for employees and associated persons to raise concerns, including anonymous reporting where practicable. Protections against retaliation for good-faith reporters align with the Public Interest Disclosure Act 1998.

Training and communication requirements specify how frequently training is provided, how policy awareness is maintained, and how the policy is communicated to third parties. The Ministry of Justice Guidance requires training to be proportionate to the risk and role of the individual.

Record keeping specifies the minimum retention period for the gifts register, due diligence records, training records, and investigation records. Six years is commonly adopted to align with the Limitation Act 1980 and HMRC record-keeping requirements.

Sanctions and consequences confirm that breach of the policy will be treated as a disciplinary offence and may result in dismissal and criminal referral, providing meaningful deterrence alongside the positive procedures.

Additional compliance elements for a Anti-Bribery and Corruption Policy (England & Wales) used in United Kingdom include: Under the Companies Act 2006, Companies House maintains the register of UK companies. Section 386 of the Companies Act 2006 sets accounting record obligations. The Competition and Markets Authority (CMA) enforces the Consumer Rights Act 2015. The Financial Conduct Authority (FCA) regulates financial services under the Financial Services and Markets Act 2000. The High Court of Justice has jurisdiction under the Senior Courts Act 1981. Forms-legal.com provides this template as a starting point for United Kingdom-compliant documentation.

Cite this page

Reference this free template in an article, syllabus, or research note:

APA

Forms Legal. (2026). Anti-Bribery and Corruption Policy (England & Wales) (United Kingdom) [Legal document template]. Forms Legal. https://forms-legal.com/uk/business/policies/anti-bribery-corruption-policy-england-wales

MLA

"Anti-Bribery and Corruption Policy (England & Wales) (United Kingdom)." Forms Legal, 2026, https://forms-legal.com/uk/business/policies/anti-bribery-corruption-policy-england-wales.

BibTeX

@misc{formslegal-anti-bribery-corruption-policy-england-wales,
  author       = {{Forms Legal}},
  title        = {Anti-Bribery and Corruption Policy (England & Wales) (United Kingdom)},
  year         = {2026},
  howpublished = {\url{https://forms-legal.com/uk/business/policies/anti-bribery-corruption-policy-england-wales}},
  note         = {Free legal document template. Based on Bribery Act 2010}
}

Also available for these jurisdictions:

Frequently Asked Questions

Based on Bribery Act 2010 — Template last modified June 2026Verify the source →

This template is provided for informational purposes only and does not constitute legal advice. Laws vary by jurisdiction and change over time. Consult a qualified attorney for advice specific to your situation.Full disclaimer

Found an error? Let us know