Policy Reference: _____________________________________________
Version: _____________________________________________
Effective Date: _____________________________________________
Review Date: _____________________________________________
Policy Owner: _____________________________________________
1. Purpose and Commitment
This Anti-Bribery and Corruption Policy (the "Policy") sets out the organisation's commitment to conducting all business activities with the highest standards of ethical conduct, in full compliance with applicable anti-bribery and anti-corruption laws in all jurisdictions in which the organisation operates.
The organisation adopts a zero-tolerance approach to bribery and corruption in all its forms. This Policy applies to all employees, officers, directors, agents, contractors, consultants, intermediaries, joint venture partners, and any other person or entity acting on behalf of the organisation (collectively, "Personnel" and "Associated Persons").
Applicable legislation includes, without limitation: the UK Bribery Act 2010; the US Foreign Corrupt Practices Act 1977 (FCPA); the Indian Prevention of Corruption Act 1988 (as amended in 2018); the EU Anti-Corruption Directive and applicable national implementing legislation; and any other anti-bribery and anti-corruption legislation applicable in the jurisdictions in which the organisation operates.
2. What This Policy Prohibits
The organisation prohibits all forms of bribery and corruption, including:
Offering, promising, giving, requesting, agreeing to receive, or accepting any financial or other advantage (a "Bribe") to or from any person, whether in the public or private sector, with the intention of inducing or rewarding improper conduct, or of gaining any commercial advantage for the organisation or any associated person;
Facilitation payments — payments made to government officials or other persons to expedite or secure the performance of a routine action to which the payer is already entitled. Such payments are prohibited even where they are customary or low in value in a particular jurisdiction;
Kickbacks — payments or other benefits offered to purchasing officers, procurement personnel, or commercial counterparties in exchange for directing business to the organisation;
Political contributions made for the purpose of obtaining or retaining a business advantage, or made without the prior written approval of the Compliance Officer;
Charitable donations or sponsorships made in circumstances where they could be construed as a Bribe or as a means of obtaining a business advantage, without the prior written approval of the Compliance Officer;
Any other conduct that would constitute an offence under applicable anti-bribery or anti-corruption legislation.
3. Gifts, Hospitality, and Entertainment
Personnel may give or receive gifts, hospitality, or entertainment only where: (a) it is not made with the intention of inducing improper conduct or influencing a business decision; (b) it is proportionate, reasonable, and consistent with normal business practice in the relevant industry and jurisdiction; (c) it would not cause embarrassment to the organisation if it became publicly known; and (d) it complies with the applicable limits set out in this Policy.
Gifts with a value exceeding _____________ per occasion, or _____________ in aggregate from or to the same party in any twelve (12)-month period, must be declared to and approved by the Compliance Officer in advance (or, where not practicable in advance, within _____ business days of receipt or giving).
Cash gifts of any amount are prohibited in all circumstances.
Gifts, hospitality, or entertainment offered to or received from government officials or public sector employees are subject to enhanced scrutiny and require pre-approval from the Compliance Officer in all cases, regardless of value.
All gifts, hospitality, and entertainment given or received shall be recorded in the organisation's gifts and hospitality register, maintained by the Compliance Officer.
4. Third-Party Due Diligence
The organisation is committed to ensuring that it does not facilitate bribery or corruption through its third-party relationships. Before engaging any agent, distributor, consultant, joint venture partner, or other intermediary who will interact with government officials or act on the organisation's behalf, appropriate due diligence shall be conducted.
Due diligence shall include, as a minimum: verification of the third party's legal identity and ownership structure; screening against applicable sanctions and debarment lists; assessment of the third party's anti-bribery compliance programme; and evaluation of whether the compensation proposed is reasonable and proportionate to the services provided.
The organisation shall not engage any third party that refuses to confirm its compliance with applicable anti-bribery laws, or where due diligence reveals a material risk of bribery or corruption.
All third-party agreements shall include an anti-bribery warranty and a right to terminate in the event of a bribery-related breach.
5. Responsibilities
Senior Management: The organisation's senior management is responsible for setting the tone at the top on anti-bribery and corruption, allocating adequate resources to compliance, and ensuring that this Policy is implemented effectively throughout the organisation.
Compliance Officer: The Compliance Officer is responsible for: (a) maintaining and updating this Policy; (b) providing training to Personnel; (c) managing the gifts and hospitality register; (d) reviewing and approving requests for gifts, political contributions, and charitable donations; (e) conducting or overseeing third-party due diligence; and (f) investigating suspected breaches. The Compliance Officer is: _____________________________________________.
All Personnel: Every member of Personnel is responsible for: (a) reading and understanding this Policy; (b) complying with its requirements at all times; (c) completing required training; (d) reporting any suspected breach or concern promptly; and (e) cooperating fully with any investigation.
6. Reporting Suspected Bribery or Corruption
Personnel who suspect or become aware of any bribery, corruption, or breach of this Policy — whether by a colleague, manager, third party, or counterparty — must report their concern immediately to the Compliance Officer.
Reports may be made in writing, by email, or through any confidential reporting channel established by the organisation. Reports may be made anonymously where the reporting mechanism permits.
The organisation adopts a strict non-retaliation policy. No Personnel shall suffer any adverse consequence, dismissal, demotion, or disadvantage for making a good-faith report of a suspected breach, even if the report turns out to be unfounded.
Any Personnel who retaliates against a good-faith whistleblower shall be subject to disciplinary action up to and including dismissal.
7. Investigations
Upon receipt of a report or concern, the Compliance Officer shall assess the matter and determine the appropriate course of action, which may include: an internal investigation; engagement of external legal counsel; suspension of the relevant activity or commercial relationship pending investigation; and, where appropriate, voluntary disclosure to the relevant regulatory authority.
Investigations shall be conducted promptly, impartially, and with appropriate confidentiality. Personnel under investigation shall be informed of the allegations against them and given a reasonable opportunity to respond.
The outcome of all investigations shall be documented and reported to senior management. Where a breach is confirmed, appropriate disciplinary or remedial action shall be taken without delay.
8. Consequences of Breach
Any Personnel who breaches this Policy shall be subject to disciplinary action, up to and including summary dismissal or termination of contract. The organisation reserves the right to report confirmed breaches to the relevant regulatory or law enforcement authorities.
Any Associated Person (including agents, distributors, or consultants) who breaches this Policy or whose conduct gives rise to a bribery risk for the organisation may have their agreement terminated immediately and may be reported to the relevant authorities.
Bribery and corruption are criminal offences in most jurisdictions. Individuals found guilty may face imprisonment, fines, and disqualification from holding directorships or other positions. The organisation may also face criminal prosecution, civil liability, and severe reputational damage.
9. Training and Awareness
All Personnel shall receive training on this Policy upon joining the organisation and at least annually thereafter.
Personnel in higher-risk roles (including sales, procurement, finance, and any role involving contact with government officials) shall receive enhanced training appropriate to their risk exposure.
Records of training attendance and completion shall be maintained by the Compliance Officer.
10. Record Keeping
The organisation shall maintain accurate and complete records of: all gifts and hospitality given and received; all charitable donations and sponsorships; all political contributions; all third-party due diligence conducted; all reports of suspected bribery or corruption; and all investigations and their outcomes. Records shall be retained for a minimum of six (6) years.
11. Review and Update
This Policy shall be reviewed by the Compliance Officer at least annually and updated as necessary to reflect changes in applicable law, business activities, or risk profile. Material changes shall be communicated to all Personnel promptly.
ACKNOWLEDGEMENT
By signing below, the undersigned confirms that they have read, understood, and agree to comply with this Anti-Bribery and Corruption Policy in full.
Name: _____________________________________________
Title: _____________________________________________
Department: _____________________________________________
Signature: _____________________________________________
Date: _____________________________________________
Doc 20 — Anti-Bribery and Corruption Policy — Neutral Template