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Anti-Bribery & Corruption Sample Policy Template

Set clear expectations for ethical business conduct. Use this customizable sample policy to address bribery and corruption risks, third-party relationships, business courtesies, financial controls and reporting.

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Two colleagues walk through a modern office hallway, engaged in conversation. The woman is holding and gesturing at a tablet, while the man listens, holding a laptop under his arm.

Establish clear anti-bribery and corruption standards

Define prohibited conduct

Give employees and third parties clear guidance on bribery, improper payments, facilitation payments and other forms of misconduct.

Address higher-risk interactions

Set expectations for interactions with public officials, gifts and hospitality, charitable donations and third-party relationships.

Strengthen oversight and reporting

Establish expectations for third-party due diligence, accurate record-keeping, internal controls and reporting suspected bribery or corruption.

Two people work together at a desk, looking intently at a computer screen. One person is sitting and using the keyboard, while the other stands nearby, holding a pencil and notepad, appearing focused and engaged in discussion.

What to include in an anti-bribery and corruption policy

A clear policy gives employees and third parties practical guidance to recognize and respond to bribery and corruption risks. This sample Anti-Bribery & Corruption Policy Template gives you a starting point you can adapt to your organization’s needs, business relationships and applicable requirements. 

Use the template to address: 

  • Definitions and prohibited forms of bribery and corruption 
  • Facilitation payments and requests for improper payments 
  • Interactions with public officials 
  • Gifts, entertainment, hospitality and travel expenses 
  • Third-party due diligence, contracts and ongoing oversight 
  • Political contributions, charitable donations and sponsorships 
  • Record-keeping, financial transparency and internal controls 
  • Reporting procedures and whistleblower protections 

The template is intended for general guidance and should be reviewed with qualified legal or compliance professionals to account for the requirements that apply to your organization and jurisdictions.

Start building your anti-bribery and corruption policy

his template is a practical starting point for defining prohibited conduct, setting expectations for higher-risk business interactions and establishing controls for preventing, detecting and responding to bribery and corruption.