Every business, big or small, faces the risk of bribery and corruption. It does not matter whether you run a startup in a co-working space or manage a multinational corporation with offices across continents. The exposure is real, the consequences are severe, and the legal liabilities can be company-ending.
Yet, so many organizations either have no policy in place or are working with a vague, outdated document that offers little practical protection. A proper anti-bribery and corruption policy is not just a compliance checkbox. It is your first line of defense, your clearest signal to employees and partners that ethical conduct is non-negotiable.
Getting this policy right matters more than most leaders realize. A well-crafted policy protects your people, your reputation, and your bottom line. Read on for three ready-to-use samples you can adapt for your organization today.
Anti-Bribery and Corruption Policy Samples
Whether you are drafting your first policy or revising an existing one, having a strong template makes all the difference. The three samples below cover different organizational sizes and contexts, giving you a flexible starting point for whichever fits best.
1. Anti-Bribery and Corruption Policy for Small and Medium-Sized Businesses
ANTI-BRIBERY AND CORRUPTION POLICY
Organization: [Company Name] Effective Date: [Date] Policy Owner: [CEO / Managing Director] Review Date: [Date]
1. Purpose
[Company Name] is committed to conducting all business activities with integrity, transparency, and full compliance with applicable laws. This policy sets out our zero-tolerance position on bribery and corruption in all forms.
2. Scope
This policy applies to:
- All employees, whether full-time, part-time, or temporary
- All contractors, consultants, and freelancers engaged by the company
- All business partners, agents, and third parties acting on behalf of [Company Name]
3. Definitions
Bribery is the offering, giving, receiving, or soliciting of anything of value with the intent to influence a business or government decision improperly.
Corruption is the misuse of entrusted power or position for personal gain.
A facilitation payment is an unofficial payment made to secure or speed up a routine action by a public official. These are prohibited under this policy, regardless of local custom or perceived business necessity.
4. Prohibited Conduct
No employee or associated person may:
- Offer, promise, give, request, or accept a bribe in any form, whether cash, gifts, hospitality, entertainment, or any other benefit
- Make or accept facilitation payments
- Use a third party to channel a bribe on behalf of the company
- Engage in any conduct that constitutes or could constitute corruption under applicable law
5. Gifts and Hospitality
Reasonable and proportionate gifts and hospitality are permitted when they:
- Are given or received openly and transparently
- Are not made with the intention of influencing a business decision
- Would not create a perception of impropriety
- Do not exceed a value of [insert local currency amount] per occasion without prior written approval from a senior manager
All gifts and hospitality given or received above [insert threshold] must be recorded in the company’s Gifts and Hospitality Register within five business days.
6. Political and Charitable Contributions
[Company Name] does not make political donations in any form. All charitable contributions must receive prior approval from the Managing Director and must not be made as a mechanism to secure business advantage.
7. Due Diligence
Before engaging any new supplier, agent, or business partner, relevant staff must conduct basic due diligence to assess bribery and corruption risk. This includes reviewing publicly available information and obtaining signed confirmation of compliance with this policy where appropriate.
8. Reporting and Whistleblowing
Any employee who suspects bribery or corruption has occurred, is occurring, or is being planned must report this immediately to their line manager or to [Compliance Contact / Email Address].
Reports can also be made anonymously via [reporting channel or hotline].
[Company Name] strictly prohibits retaliation against anyone who raises a concern in good faith. Any employee found to have victimized a whistleblower will be subject to disciplinary action.
9. Consequences of Violation
Breach of this policy is a serious disciplinary matter. Depending on the severity of the breach, consequences may include:
- Formal written warning
- Termination of employment
- Referral to law enforcement authorities
Third parties found to be in breach of this policy will have their engagement with [Company Name] terminated immediately.
10. Training
All employees will receive training on this policy at the time of joining and at least once every two years thereafter. Completion of training is mandatory.
11. Review
This policy will be reviewed annually or following any significant regulatory change. The Managing Director holds overall responsibility for maintaining and updating this policy.
I confirm that I have read, understood, and agree to comply with this Anti-Bribery and Corruption Policy.
Employee Name: _________________ Signature: _________________ Date: _________________
2. Anti-Bribery and Corruption Policy for Large Corporations and Regulated Industries
ANTI-BRIBERY AND CORRUPTION POLICY
Organization: [Company Name] Policy Number: [Reference] Version: [1.0] Effective Date: [Date] Policy Owner: Chief Compliance Officer Approved By: Board of Directors Next Review Date: [Date]
1. Statement of Commitment
[Company Name] and all of its subsidiaries, affiliates, and associated entities (collectively referred to as “the Group”) maintain an absolute commitment to conducting business honestly, ethically, and in full compliance with all applicable anti-bribery and anti-corruption laws.
This includes, but is not limited to, compliance with:
- The UK Bribery Act 2010
- The US Foreign Corrupt Practices Act (FCPA)
- The OECD Convention on Combating Bribery of Foreign Public Officials
- All applicable local laws in each jurisdiction where the Group operates
The Group operates a zero-tolerance policy toward all forms of bribery and corruption. No business outcome, however valuable, justifies a breach of this policy.
2. Scope of Application
This policy applies globally to:
- All directors, officers, employees, and temporary staff of the Group
- All subsidiaries and joint ventures where the Group holds a controlling interest
- All third parties operating on behalf of the Group, including agents, distributors, consultants, contractors, and subcontractors
3. Key Definitions
| Term | Definition |
|---|---|
| Bribery | Offering, giving, receiving, or soliciting anything of value to influence the actions of an individual in a position of authority |
| Corruption | Dishonest or fraudulent conduct by those in positions of power, typically involving the abuse of that power for personal or corporate gain |
| Public Official | Any person holding a legislative, administrative, or judicial position; any person performing a public function; or any official of a public international organization |
| Facilitation Payment | A payment made to a low-level official to secure or expedite performance of a routine governmental action |
| Kickback | A payment made to someone in exchange for facilitating a transaction, contract, or business arrangement |
4. Specific Prohibitions
The following conduct is strictly prohibited under this policy:
4.1 Bribing a Public Official No Group employee or associated party may offer, promise, or give a financial or other advantage to a public official with the intention of influencing them in their official capacity or to obtain or retain business.
4.2 Bribing in the Private Sector No Group employee or associated party may offer, promise, or give a financial or other advantage to any individual in the private sector with the intention of influencing that person to perform their function improperly.
4.3 Receiving a Bribe No Group employee may request, agree to receive, or accept a financial or other advantage as an inducement or reward for performing their function improperly.
4.4 Facilitation Payments All facilitation payments are prohibited. If an employee is pressured to make a facilitation payment, they must refuse, record the incident, and report it immediately to the Compliance function.
4.5 Third-Party Conduct Using a third party as a conduit to offer or pay a bribe is equally prohibited. Due diligence must be conducted on all third parties, and all third parties must contractually commit to compliance with anti-bribery laws.
5. Gifts, Hospitality, and Expenses
5.1 General Principles All gifts, hospitality, and expenses must be:
- Reasonable and proportionate
- Consistent with normal business courtesies in the relevant sector and jurisdiction
- Made openly, with proper authorization and recording
- Not offered or received at a time when a tender or business decision is pending
5.2 Thresholds and Approval Requirements
| Value | Action Required |
|---|---|
| Below [Amount] | Permitted with line manager awareness |
| [Amount] to [Amount] | Requires line manager pre-approval and register entry |
| Above [Amount] | Requires Compliance Officer pre-approval and Board-level register entry |
| Any gift to/from a Public Official | Always requires Compliance Officer pre-approval, regardless of value |
5.3 Prohibited Gifts Cash, cash equivalents, or gifts that could be construed as inappropriate are always prohibited.
6. Charitable Contributions and Sponsorships
All charitable donations and sponsorships must:
- Be made through official Group channels only
- Receive prior written approval from the Compliance Officer and CFO
- Not be made to organizations connected to current or potential business counterparties
- Be publicly disclosed in accordance with applicable laws
7. Political Contributions
The Group does not make direct or indirect political contributions in any jurisdiction. This prohibition covers monetary contributions, in-kind support, and the use of corporate resources for political purposes.
8. Third-Party Due Diligence
Before engaging any third party in a commercial relationship, the responsible business unit must:
- Complete a Third-Party Risk Assessment using the Group’s standard framework
- Conduct enhanced background screening for any third party operating in a high-risk jurisdiction or sector
- Obtain a signed Anti-Bribery Compliance Certification from the third party
- Include appropriate anti-bribery warranties and termination rights in all contracts
Due diligence must be reviewed and refreshed at least every three years for ongoing relationships.
9. Books, Records, and Internal Controls
[Company Name] maintains accurate books and records in accordance with applicable accounting standards. No employee may:
- Create false or misleading records to conceal a bribe or corrupt payment
- Approve payments without proper documentation and business justification
- Circumvent internal approval and authorization controls
10. Reporting Obligations and Speak-Up Culture
Employees have both a right and a responsibility to report any suspected bribery or corruption. Reports can be made through any of the following channels:
- Direct line manager (where appropriate)
- Compliance Officer at [email address]
- [Company Name] Ethics Hotline at [telephone number] or [web portal link]
The Ethics Hotline accepts anonymous reports and is operated by an independent third party. All reports are treated with strict confidentiality.
Non-Retaliation: Any employee who raises a concern in good faith will be fully protected. Retaliation in any form is a serious disciplinary offense.
11. Responding to Suspected Violations
All reported concerns will be investigated promptly, confidentially, and impartially by the Compliance function or, where appropriate, by external legal counsel. Findings will be reported to the Audit Committee.
Substantiated violations will result in:
- Disciplinary action up to and including termination of employment
- Civil or criminal referral to the relevant authorities
- Termination of third-party relationships
12. Training and Awareness
| Group | Training Requirement |
|---|---|
| All employees | Mandatory online training at onboarding, and every two years |
| Senior management and directors | In-person or facilitated training annually |
| High-risk roles (procurement, finance, sales) | Enhanced role-specific training annually |
| Third parties | Access to Group compliance training materials upon request |
Training completion is tracked by HR and reported quarterly to the Compliance Committee.
13. Policy Governance and Review
The Chief Compliance Officer holds day-to-day responsibility for this policy. The Board of Directors retains overall accountability for the Group’s anti-bribery and corruption framework. This policy is reviewed annually and following any material change in applicable law, business structure, or risk environment.
3. Anti-Bribery and Corruption Policy for Non-Profit Organizations and NGOs
ANTI-BRIBERY AND CORRUPTION POLICY
Organization: [Non-Profit / NGO Name] Policy Reference: [Reference Number] Effective Date: [Date] Approved By: Board of Trustees / Executive Director Review Date: [Date]
1. Our Commitment
[Organization Name] exists to serve its mission and the communities it supports. Upholding the trust of our donors, partners, beneficiaries, and the public is fundamental to everything we do. We are committed to the highest standards of integrity and accountability in all our operations.
This policy reflects our firm commitment to preventing bribery and corruption, protecting our organization’s resources, and safeguarding our reputation.
2. Who This Policy Covers
This policy applies to all individuals working with or for [Organization Name], including:
- Paid staff (full-time, part-time, and temporary)
- Board members and trustees
- Volunteers and interns
- Consultants, contractors, and sub-grantees
- Partner organizations receiving funding or resources from us
3. Our Zero-Tolerance Position
[Organization Name] operates a zero-tolerance approach to bribery and corruption. This means:
- We will not offer, pay, or authorize a bribe to anyone, including government officials, partners, or service providers
- We will not accept a bribe or improper inducement from any individual or organization
- We will not allow any individual to act on our behalf in a manner that breaches this policy
4. Specific Risks in Our Operating Context
Non-profit and humanitarian organizations can face unique bribery risks, including:
- Requests for payments to access communities or beneficiaries
- Pressure from local officials to make unofficial “processing fees”
- Diversion of aid or resources intended for beneficiaries
- Fraudulent reporting by implementing partners or sub-grantees
All such situations must be reported immediately. No staff member is expected to comply with demands that breach this policy.
5. Gifts and Hospitality
We recognize that in many of the communities and countries where we work, the giving and receiving of modest gifts is a customary expression of respect. We respect these traditions while maintaining clear boundaries.
Acceptable:
- Modest, culturally appropriate gifts of low monetary value received in the course of official duties
- Hospitality that is reasonable, proportionate, and openly recorded
Not Acceptable:
- Any gift of cash or cash equivalents
- Gifts or hospitality intended to influence a procurement or funding decision
- Repeated or cumulative gifts from the same source that, taken together, exceed [threshold amount]
All gifts received above [threshold amount] must be declared to the line manager and recorded within five working days.
6. Donor Funds and Financial Integrity
All funds received from donors, governments, and institutional funders must be used solely for their intended purpose in accordance with grant or donation agreements. Misappropriation, diversion, or improper use of donor funds constitutes a serious breach of this policy and may constitute fraud under applicable law.
Staff with financial responsibilities must:
- Adhere to all financial controls and authorization procedures
- Maintain accurate and complete financial records
- Report any irregularities immediately to the Finance Manager or Executive Director
7. Due Diligence on Partners and Sub-Grantees
Before entering a partnership or disbursing funds to a sub-grantee or implementing partner, [Organization Name] will conduct proportionate due diligence. At a minimum, this includes:
- Reviewing the organization’s governance and accountability structures
- Confirming it has its own anti-bribery or anti-corruption policy in place
- Including appropriate compliance requirements in all partnership agreements
8. Reporting Concerns
Anyone who suspects that bribery or corruption is taking place, has taken place, or is being planned, must report it. You can do this by:
- Speaking directly to your line manager (if not implicated)
- Contacting the Executive Director at [email address]
- Submitting a report to the Board of Trustees at [email address]
- Using our confidential reporting mechanism at [reporting channel]
Anonymous reports are accepted. All concerns will be investigated promptly and confidentially. [Organization Name] is firmly committed to protecting anyone who raises a concern in good faith from any form of retaliation.
9. Consequences of Breach
A breach of this policy by a staff member will be treated as gross misconduct and may result in immediate dismissal. Breaches by volunteers, consultants, or partners will result in termination of their engagement with [Organization Name]. Where appropriate, cases will be referred to law enforcement authorities or reported to relevant regulatory bodies and funders.
10. Training and Communication
All staff will receive training on this policy as part of their induction and annually thereafter. This policy will be made available on our website and communicated to all partners and sub-grantees at the start of each engagement.
11. Review and Accountability
This policy is reviewed annually by the Executive Director and presented to the Board of Trustees for approval. The Executive Director holds operational responsibility for implementation. The Board of Trustees retains overall governance responsibility for anti-bribery and corruption compliance across the organization.
Wrapping Up
A strong anti-bribery and corruption policy is not a nice-to-have. It is a non-negotiable foundation for any organization that takes its legal obligations and ethical reputation seriously. The three samples above give you a practical starting point, whether you are a lean SME, a global corporation, or a mission-driven non-profit.
Pick the sample that best matches your organization’s size, structure, and operating environment. Adapt the language to reflect your specific context, insert your local legal requirements, and make sure your team actually reads it. A policy that lives in a folder and never gets communicated is no policy at all.