Anti-bribery policy template
Copy the text below and replace everything in square brackets with your company details.
1. Purpose
[Company Name] does business honestly and does not pay or accept bribes. This policy sets out the rules that every employee and business partner must follow, and explains how to report a request for a bribe or an offer of one.
2. Scope
The policy applies to all employees and directors of [Company Name] and to every third party acting for us, including agents, liaison consultants, distributors, customs brokers, contractors and consultants. It covers dealings with government officials and with private businesses alike.
3. Definitions
- Bribe: anything of value, such as cash, gifts, hospitality, jobs for relatives, discounts, loans or donations, offered, promised, given, requested or accepted to improperly influence a decision or gain an advantage.
- Government official: an employee of any central, state or local government body, public sector undertaking, regulator or court, and anyone acting in an official capacity.
- Facilitation payment: a small unofficial payment demanded to speed up a routine action, such as releasing a file or scheduling an inspection.
- Third party: any person or firm that acts on behalf of the Company.
4. Policy
- No employee or third party may offer, promise, give, request or accept a bribe, directly or through anyone else.
- Facilitation payments are prohibited, however small or customary they may seem.
- Payments to government bodies are limited to official fees paid against an official receipt.
- No political contribution is made on behalf of the Company without board approval, and only as the law permits.
- Donations and CSR spending go only to registered organizations, with approval from [Approver Designation], and never to influence a business decision.
- Gifts and hospitality are governed by the Gifts and Hospitality Policy.
- Every payment is recorded accurately in the books. Off-the-books accounts and cash funds are not allowed.
- No employee will be penalised for refusing to pay a bribe, even if the Company loses business as a result.
5. Procedure
- Before appointing an agent, liaison consultant or distributor, the business owner completes a due diligence check covering ownership, reputation, links with officials and whether the fee is reasonable for the work.
- Contracts with third parties include an anti-bribery clause and a right to terminate for breach.
- Third parties are paid only by bank transfer against invoices that describe the services.
- Any request for a bribe or facilitation payment is reported to [Compliance Officer Name] at [Email Address] within [24] hours, stating who asked, when and for what.
- Red flags to report include requests for cash or payment to a personal account, an agent suggested by the official, commissions well above normal rates, vague invoices, and requests to route money through another firm or country.
- A breach of this policy is major misconduct under the Disciplinary Action Policy, and third-party contracts may be terminated.
6. Responsibilities
- Board and management: set the tone, approve the policy and back employees who refuse to pay.
- Compliance officer: advise, receive reports, keep the due diligence register and arrange training.
- Finance: reject payments without proper documents and review unusual expenses.
- Employees and third parties: refuse, record and report.
7. Exceptions
The only exception is a payment demanded under a threat to a person's safety or liberty. In that situation, pay only what is needed to stay safe and report it to the compliance officer as soon as possible so it can be recorded correctly.
8. Review
The compliance officer reviews this policy every [12] months together with a short risk assessment of the licences, inspections, tenders and customer segments where requests are most likely, and updates training for the staff most exposed.
What to include
Facilitation payments named and banned
Say plainly that speed money is bribery, however small or customary. Staff at checkposts, government offices and ports need that sentence more than any other.
Third parties are covered
Bribes often travel through agents, liaison consultants and distributors. Due diligence, contract clauses and bank-only payments close the route.
Backing for refusal
Promise that nobody will be penalised for refusing to pay, even if an order is lost or a clearance is delayed. Without that promise, employees assume paying is expected.
A red flag list
List warning signs your finance and purchasing teams can spot: cash requests, payments to personal accounts, inflated commissions and vague invoices.
Accurate books
Require every payment to be recorded as what it is. Bribes are often hidden as miscellaneous expenses, consultancy or transport charges.
Safety exception
Allow a payment only when safety or liberty is under threat, and require it to be reported at once. This is realistic and keeps the exception narrow.
Common mistakes to avoid
- Allowing speed money at checkposts or government offices because everyone else pays it.
- Hiring a liaison agent on a success fee without asking what the fee actually pays for.
- Recording cash paid to officials as miscellaneous or conveyance expenses.
- Training only senior managers when drivers, liaison staff and site supervisors face the requests.
- Letting sales teams give costly gifts to a customer's purchase officers during a tender.
Run it in ZeniaHR
ZeniaHR does not track payments to third parties, so due diligence files and payment approvals stay with finance. Set up anti-bribery training in Learning as a mandatory program for purchasing, sales, liaison and finance staff, with a validity in months, so expired certificates show up in the compliance view. Publish the policy on the Company Wall with required acknowledgement, and keep signed annual compliance declarations in Employee Documents.
See it on your own data
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Book a free demoSee pricingFrequently asked questions
What is an anti-bribery policy?
An anti-bribery policy is a company rule that forbids employees and anyone acting for the company from offering, giving, requesting or accepting bribes in any form. It defines bribes and facilitation payments, sets rules for agents and gifts, lists red flags, and explains how to report a request. It protects both the company and the employees who face pressure.
What is a facilitation payment?
A facilitation payment is a small unofficial payment demanded to speed up a routine government action, such as releasing a file, scheduling an inspection or clearing a consignment. It is a form of bribery even when it is small and customary. A good policy bans it outright and tells employees to report any demand the same day.
Why should an anti-bribery policy cover agents and distributors?
Because bribes are often paid through intermediaries: a liaison agent's success fee, a distributor's extra discount or a broker's miscellaneous charges. If the policy covers only employees, the same payment simply moves to a third party. Due diligence, anti-bribery clauses in contracts and bank-only payments close that gap.
What should an employee do if an official asks for a bribe?
Refuse politely, ask for the official fee and receipt, and report the request the same day to the compliance officer with the official's name, office, date and what was demanded. The company should back the refusal, escalate through proper channels if work is held up, and never penalise the employee for delays or lost business.