Anti-Bribery and Corruption Policy Template

Anti-Bribery and Corruption Policy

Purpose of Anti-Bribery and Corruption Policy

This Anti-Bribery and Corruption Policy explains [Company Name] expectations and requirements for preventing bribery, corruption, and related improper conduct. The policy exists to protect the integrity of the organization, ensure ethical behavior by employees and representatives, and maintain stakeholder trust by reducing legal, financial, and reputational risk.

Scope

This policy applies to all employees, officers, contractors, consultants, agents, and any third parties acting on behalf of [Company Name] worldwide. All business activities and interactions that could create an appearance of bribery or corruption are covered, including relationships with public officials, vendors, customers, and partners.

Principles and Rules

[Company Name] requires honest and transparent conduct in all business dealings. Employees must not offer, give, solicit, or accept bribes or improper payments in order to obtain or retain business, secure an advantage, or influence a decision.

• Prohibited conduct includes offering or accepting cash bribes, kickbacks, facilitation payments, inappropriate gifts, or any other advantage intended to improperly influence a business outcome.
• Gifts, hospitality, and entertainment must be reasonable, proportionate, and infrequent, and must not create a conflict of interest or the appearance of impropriety.
• Employees must declare any relationship or interest that could create a conflict with their duties to [Company Name].
• Third parties acting on behalf of [Company Name] must be subject to appropriate due diligence and contractual anti-corruption commitments.

Gifts, Hospitality, and Expenses

Modest and customary gifts or hospitality that are lawful, transparent, and given in good faith are permitted when they do not influence business decisions. Employees must follow any internal guidance on allowable value, approvals, and recordkeeping.

• Gifts or hospitality that could be perceived as a reward or inducement are not permitted.
• All business-related expenses must be accurately recorded and supported by receipts.
• Prior approval is required for any gift or hospitality that is outside normal practice or that could create a perception of undue influence.

Third Party Agents and Intermediaries

Engagement of agents, consultants, or other intermediaries requires due diligence to confirm their integrity and suitability. Contracts with third parties should include anti-corruption clauses and the right to audit or terminate for breach.

Reporting and Escalation

Employees must promptly report any concerns, suspicions, or incidents of bribery or corrupt conduct. Reports should be made to a manager, HR, or the designated compliance contact. Reports may be made confidentially and will be handled with appropriate discretion.

• Do not investigate allegations personally beyond what is necessary to report the concern.
• Protect anyone who reports concerns in good faith from retaliation.

Approval Process

Requests for exceptions, approvals for non-standard gifts or hospitality, or engagements of third parties must follow the defined approval workflow. Managers are responsible for reviewing and approving routine requests, documenting rationale, and escalating higher risk matters to HR or the compliance function.

• Managers must verify that requests comply with this policy and maintain records of approvals.
• HR will assist in assessing conflicts of interest and advising on disciplinary or corrective actions where appropriate.
• Significant exceptions or high-risk situations require written approval from the relevant senior officer or compliance leader prior to proceeding.

Training and Responsibilities

[Company Name] will provide training and guidance on anti-bribery and corruption requirements. Employees are responsible for completing required training and applying the principles of this policy in day-to-day activities.

Recordkeeping and Monitoring

Accurate records must be maintained for transactions, approvals, due diligence, and reported incidents. [Company Name] will monitor compliance and periodically review processes to ensure effectiveness.

Non-Compliance

Failure to comply with this Anti-Bribery and Corruption Policy may result in disciplinary action up to and including termination of employment or contract. Non-compliance may also expose individuals and [Company Name] to criminal and civil penalties. Investigations will be conducted fairly, promptly, and impartially.

Note

This policy may be updated from time to time to reflect changes in best practice or organizational requirements. Employees are expected to remain informed of the current policy and to contact HR for clarification or assistance in applying this policy.