Bribery Act, Compliance & Other Policies
With the entry into force of the Bribery Act 2010, keeping business practices clean and clear has never been more important.
The guidance notes and policy document templates in this subfolder have been crafted to aid businesses in compliance with anti-bribery legislation and help to provide clarity with regards to the provision of hospitality, and to business ethics and fair trade.
- Guidance Notes – Bribery Act 2010
- Bribery Act Policy
- Business Expenses Policy
- Hospitality and Gifts Policy
- Business Ethical Policy
- Fair Trade Policy Statement Template
- Whistleblowing Policy
- Anti-Money Laundering Policy Template
- Business Wide Anti-Money Laundering Risk Assessment
- Anti-Money Laundering Customer Identification Checklist
Bribery Act, Compliance & Other Policies is part of Business . Just £38.50 + VAT provides unlimited downloads from Business for 1 year.
Frequently Asked Questions
Does the Bribery Act apply to my business even if I never pay bribes myself?
Yes. Under section 7 of the Bribery Act 2010 your business can be guilty of failing to prevent bribery if a person associated with it, such as an employee, agent or contractor, bribes someone to win business for you. This is a strict liability offence, so you can be liable without any intent or knowledge on your part. Your protection is having adequate procedures in place. The policies in this sub-folder are built to provide them.
What is the adequate procedures defence and how do I get it?
Adequate procedures are the anti-bribery measures that give your business a defence to the section 7 offence. The Ministry of Justice guidance sets out six principles to shape them: proportionate procedures, top-level commitment, risk assessment, due diligence, communication including training and monitoring and review. There is no tick-box template that guarantees the defence, but policies built around these principles and actually implemented are what count. This sub-folder's documents follow them.
Can corporate hospitality or gifts breach the Bribery Act?
They can, if they cross the line into improperly influencing someone. Reasonable and proportionate hospitality that is genuinely to build relationships or promote your business is not caught, and the Ministry of Justice guidance recognises normal corporate hospitality as legitimate. The risk is lavish or well-timed gifts intended to secure an advantage. A clear gifts and hospitality policy, setting limits and approvals, keeps you on the right side. This sub-folder provides one.
Does the Bribery Act apply to small businesses?
Yes. The section 7 offence applies to any relevant commercial organisation regardless of size, so a small business is not exempt. The good news is that adequate procedures are meant to be proportionate: a small, low-risk firm needs far less than a large multinational, and the first principle in the guidance is proportionality. So keep your procedures sensible for your size rather than skipping them. This sub-folder's templates are drafted to be adapted to your scale.