Anti-Bribery Policy Template
The rules on gifts, facilitation payments, agents and donations.
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| Applies to | [who it applies to] |
| Owner | [owner] |
| Effective from | October 14, 2026 |
| Next review | [date] |
1. The rule
This organization does not pay bribes and does not accept them. That applies everywhere it works, to everyone acting on its behalf, and whatever the local custom is said to be. Losing business is an acceptable outcome; paying for it is not.
2. What this means in practice
[add one rule per line]
3. Gifts and hospitality
Modest hospitality given openly and recorded is not a bribe. Anything above [limit] needs written approval before it is offered or accepted. Nothing at all is offered or accepted while a tender involving that party is open.
4. The register
[how gifts and hospitality are recorded]
5. Raising a concern
[who to tell, and the protection given to whoever tells]
What is an Anti-Bribery Policy?
An anti-bribery policy sets out what your people may and may not give or accept, and who decides in the grey cases. It exists because bribery law reaches the organisation, not only the individual who paid: several regimes make a company answerable for what an employee, agent or distributor does on its behalf, and the main defence is having had adequate procedures in place and actually enforced. A policy nobody has read is not that.
Any organisation that sells to government, uses agents or distributors, operates across borders, or wants to pass supplier due diligence needs one, and large customers increasingly ask for a copy before onboarding. The people who use it are ordinary staff at ordinary moments: a salesperson deciding whether to pay for a client's dinner during a tender, a buyer offered hospitality by a supplier, a finance clerk looking at an unusual consultancy invoice, and the logistics manager who has just been asked for a cash payment to release a shipment at a border.
Regimes differ in ways that matter, so identify which apply to you. The UK Bribery Act covers commercial bribery as well as public officials, reaches conduct abroad, and creates a corporate failure-to-prevent offence with an adequate procedures defence. The US Foreign Corrupt Practices Act reaches issuers and US persons and contains a narrow facilitation payment exception that the UK does not have. India's Prevention of Corruption Act covers giving as well as taking. Canada, Australia and EU member states each have their own, plus local rules on gifts to public servants and political donations.
The policy is not a defence by itself. Regulators look at your risk assessment, your due diligence on third parties, training, monitoring, and what happened when somebody raised a concern. It does not decide individual cases — that is what the approvals route and the register are for. It does not replace anti-bribery clauses, audit rights and termination rights in agent and distributor contracts. And it protects nobody who follows the paperwork while knowing the payment is a bribe.
What to put in an Anti-Bribery Policy
These are the details this template asks for. Anything left blank is marked in red on the preview so you can see what is still missing.
| Field | What goes in it |
|---|---|
| Issuing organisation | For example: Maple Grove Homeowners Association |
| Organisation address | For example: 1420 Kinnear Road, Columbus, OH 43212 |
| Who this applies to | For example: All employees, contractors and anyone posting on a company account |
| Policy owner | For example: Head of People |
| Next review | Free text |
| The rules | One per line |
| Gifts and hospitality limit | For example: 2,500 in value, and everything declared in the register |
| The register | For example: Every gift or hospitality offered or received, whatever the value, is recorded in the… |
| How to raise something | For example: Tell your line manager. If it involves your line manager, tell the Managing Director. If… |
| If the policy is not followed optional | For example: Unapproved absence may be treated as unauthorised and dealt with under the disciplinary… |
How to write an Anti-Bribery Policy
Define bribery with examples from your sector
Say what is covered: cash, gifts, hospitality, travel, charitable and political donations, sponsorship, internships or jobs for relatives, and unusual discounts or rebates. Then give examples people recognise — a supplier offering tournament tickets during a live tender, a customs agent asking for a payment to release goods. Abstract definitions get skimmed; a concrete example is what somebody remembers at the moment it matters.
Set thresholds and an approvals route
State the value above which gifts and hospitality need approval, who approves, and where the record is kept. Make it a real register with a named owner rather than a mailbox nobody reads. List what is never permitted at any value: cash or cash equivalents, anything during a live tender, anything to a public official without specific approval. Apply a lower threshold to public sector contacts.
Address facilitation payments explicitly
Take a position and write it down. If your organisation prohibits them, say so, and set out the exception for genuine safety situations: pay if you or a colleague are at risk, then report it the same day to a named person and record it accurately in the books. Silence on this point is what leaves staff improvising at a border post at midnight.
Cover third parties and due diligence
Agents, distributors, resellers, freight forwarders, consultants and joint venture partners are where most corporate exposure arises. Set out the checks run before appointment, the contract terms required, how commission rates are reviewed, and what happens when payment is requested to a third country or to an entity other than the one you contracted with. Record the file for each intermediary.
Give a reporting route and protect reporters
Name at least two ways to raise a concern, including one outside the person's own management line, and say whether a confidential external line exists. State plainly that nobody will suffer for raising a genuine concern and that they must not investigate it themselves. Set out how reports are recorded, who reviews them, and how the outcome is fed back to the person who reported.
Common mistakes
- Adopting a policy that reflects only one country's law, so a US-derived document with a facilitation payment carve-out fails to satisfy a regime that has no such exception.
- Setting a gift and hospitality threshold and then never maintaining the register, so the absence of records is the first thing an investigator finds and an honest organisation looks careless.
- Excluding agents, distributors and joint ventures from the policy's scope, which is precisely where most corporate liability for bribery actually arises.
- Making the line manager the only route for raising a concern, so a concern about that manager — a common case — has nowhere at all to go.
- Publishing the policy without training or acknowledgement records, leaving you with the document but no evidence anyone was told, which is what an adequate procedures argument turns on.
Frequently asked questions
Do small businesses need an anti-bribery policy?
Size does not remove exposure, and a policy is increasingly a procurement requirement — large customers ask for one before onboarding a supplier. A short, genuinely applied policy with a working approvals log suits a small firm far better than a long one nobody follows. Scale the procedures to your real risk; overseas agents and public sector customers raise it sharply.
Are facilitation payments legal?
The answer differs by regime. Some laws contain a narrow exception for routine government action; others, including the UK's, do not, so paying can be an offence even where local practice tolerates it. Because one payment can be lawful under one country's law and criminal under another that also applies to you, take advice on the specific situation rather than following local custom.
What gift value is acceptable?
There is no universal figure. Set a threshold that suits your sector and your customers, apply a much lower one to public officials, and require approval and recording above it. Timing and intent matter more than the number: modest hospitality offered during a live tender or an open negotiation is a problem that no threshold makes acceptable.
Who should own an anti-bribery policy?
A named senior person with board or owner-level visibility, because regulators look for tone from the top and an unowned policy drifts. In a small organisation that may be the finance director or general counsel; in a larger one, a compliance function. Whoever owns the policy should also own the gifts register, the third-party due diligence files and the training records.
How often should the policy be reviewed?
At least annually, and immediately after anything that changes your risk profile: entering a new country, appointing agents, winning a public sector contract, completing an acquisition, or dealing with an incident. Record the date of each review and what changed. A policy last touched years before an incident is much harder to defend than a short one that is visibly maintained.
This page explains general practice and is not legal advice. Requirements differ between countries and, in some cases, between states — check what applies where the document will be used.