This anti-bribery policy template has 5 pages and is a MS Word file type listed under our business plan kit documents.
Sample of our anti-bribery policy template:
ANTI-BRIBERY POLICY [COMPANY NAME] ("Company," "Us," "We") is dedicated to conducting all its business in an honest and ethical manner. The Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships. Our Company strives to attain its mission through compliance with high legal and ethical standards. We do not tolerate any form of bribery, embezzlement, or corruption, and will uphold all laws countering bribery, fraud, and corruption in all forms. POLICY The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company's business is conducted in a socially responsible manner. POLICY STATEMENT Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised, or provided to gain any commercial, contractual, regulatory, or personal advantage. It is our policy to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws in [COUNTRY] in respect of our conduct both at home and abroad. Bribery and corruption are punishable for individuals by up to [NUMBER OF YEARS] years' imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously. SCOPE In this policy, "third party" means any individual or organization Employees come into contact with during the course of their work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties. This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, home workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as Employees in this policy). This policy covers: Bribes; Gifts and hospitality; Facilitation payments; Political contributions; Charitable contributions. BRIBES Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, Employees must not bribe a foreign public official anywhere in the world. GIFTS AND HOSPITABILITY Employees must not offer or give any gift or hospitality: which could be regarded as illegal or improper, or which violates the recipient's policies; or to any public employee or government officials or representatives, or politicians or political parties; or which exceeds [SPECIFY AMOUNT] in value for each individual gift or [SPECIFY AMOUNT] in value for each hospitality event (not to exceed a total value of [SPECIFY AMOUNT] in any financial year), unless approved in writing by the Employee's manager. Employees may not accept any gift or hospitality from our business partners if: it exceeds [SPECIFY AMOUNT] in value for each individual gift or [SPECIFY AMOUNT] in value for each hospitality event (not to exceed a total of [SPECIFY AMOUNT] in any financial year), unless approved in writing by the Employee's manager; or it is in cash; or there is any suggestion that a return favor will be expected or implied. Where a manager's approval is required above, if the manager is below director level, then approval must be sought from an appropriate director. If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the Employee's manager and donated to charity. We appreciate that the practice of giving business gifts varies between countries and regions, and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered. Within these parameters, local management may define specific guidelines and policies to reflect local professional and industry standards. Where this policy requires written approval to be given, the Company Secretary shall put in place a process to maintain a register of all such approvals. FACILITATION PAYMENTS AND KICKBACKS Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low-level officials to obtain a level of service which one would normally be entitled to. Our strict policy is that facilitation payments must not be paid. We recognize, however, that our Employees may be faced with situations where there is a risk to the personal security of an Employee or his/her family and where a facilitation payment is unavoidable, in which case the following steps must be taken: Keep any amount to the minimum; Create a record concerning the payment; and Report it to the line manager. In order to achieve our aim of not making any facilitation payments, each business of the Company will keep a record of all payments made, which must be reported to the Company Secretary, in order to evaluate the business risk and to develop a strategy to minimize such payments in the future.
