Anti-Bribery Policy

The policy is the base document of a firm's anti-bribery programme. It states in plain terms that the organisation does not offer, give, request or accept bribes, directly or through others. It defines key terms and then deals with common risk points: gifts and hospitality, facilitation payments, political and charitable donations, dealings with public officials, use of agents and intermediaries, and conflicts of interest. It sets approval limits, record-keeping duties, and a route for raising concerns without retaliation. It also names who owns the policy, usually the compliance function, and what happens to those who break it. Visible backing from senior leaders gives it weight. The policy applies to employees, directors and often to agents and suppliers by contract. It is supported by training, a risk assessment and due diligence on third parties. When a case begins, investigators ask for this document first, then check whether anyone followed it.

A manufacturer's anti-bribery policy says gifts to public officials are not allowed, and gifts to private business contacts above a small value need written approval from compliance. An employee wants to send a costly hamper to a customs officer at year end. She checks the policy, sees the ban, and asks compliance for a safe alternative.