This policy procedure sets out how bribery risk is assessed, controlled and reported across the business, and points to the registers, declarations and forms that hold the detail.

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This policy template is supplied in fully editable MS Word format and can be easily customised and edited. The document uses pre-defined style formatting throughout, with all text in Calibri font for improved readability.
The following document labelling is included in the footer:

• Policy number and title
• Information-classification
• Version
• Page number / total pages

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Further Reading

Further guidance on anti-bribery management:

• Bribery Risk Management
• ISO 37001 Clause 8.2 - Due Diligence
• ISO 37001 Clause 8.10 - Investigating and Dealing with Bribery
• ISO 37001 knowledge base

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Anti-Bribery Policy Procedure Template

The Anti-Bribery Policy Procedure is a Word template that sets out how a business identifies bribery risk and prevents bribery. It covers the anti-bribery management system and its compliance team, awareness and competence, risk assessment and due diligence, supplier bribery risk, financial and non-financial controls, business associates, declarations, gifts and hospitality, and reporting and investigating concerns.

It is written for an anti-bribery management system meeting ISO 37001 and works alongside a publicly shareable anti-bribery policy. It has Title, File Location, Issue No, Issue Date, Controlled By and Approved By fields, an Amendment Record and a Business Use information classification in the footer.

What the Policy Covers

• Summary, scope and management system - the purpose, scope and applicability, how the management system and public policy fit together, and the basic rules on bribes and conflicts of interest
• Anti-bribery compliance team - duties of the governing body and top management, the anti-bribery lead, and an anti-bribery function provided by the lead or a focus committee
• Awareness and competence - staff awareness at induction and annual review, contracts referring to the management system, checks on higher risk roles and training for business associates
• Risk assessment and due diligence - an annual bribery risk assessment, a risk rating matrix, due diligence where risk is moderate or substantial, and guidance on what to consider
• Managing supplier bribery risks - bribery risk in supplier appraisal and contract review, and a bribery risk rating for suppliers scored on frequency, value and general risk
• Bribery controls - financial controls including a spending limits table, transaction and good practice controls, contractual protection, framework agreements and handling inadequate controls
• Business associates and declarations - risk assessing business associates, listing higher risk associates with their controls, due diligence before engaging them and periodic compliance declarations
• Gifts, hospitality and reporting concerns - acceptable gifts and hospitality, donations, raising concerns openly or anonymously, recognising bribery, whistleblowing protection and how investigations are run

Built for an ISO 37001 Management System

• Due diligence required wherever a substantial bribery risk is identified, prioritised by level of risk
• A bribery risk rating for listed suppliers, scoring frequency, value and general risk out of 15
• A spending limits table setting quotes, due diligence and approval levels by order value
• Annual compliance declarations from staff in positions where there is any bribery risk
• Investigations run by independent, competent people, with findings reported to top management and the anti-bribery function

Who Needs an Anti-Bribery Policy Procedure?

Businesses implementing an anti-bribery management system, including those working towards ISO 37001, and the anti-bribery lead, compliance committee and managers who carry out risk assessment, due diligence and investigations.

Included in the ISO 37001 Toolkit

This policy is part of the ISO 37001 Toolkit and the integrated toolkits that include it.

How the Policy Fits Together

Due diligence and higher risk roles are summarised on F-IMS34 Anti-bribery Compliance Register, with individual reviews logged on F-AB4 Bribery Due Diligence Review and supplier risk scored on ER33 Key Supplier Bribery Risk Register. Higher risk associates go on F-IMS35 Business Associate Register, declarations are made on F-AB3 Bribery Commitment Declaration and gifts are recorded on ER22 Hospitality and Gifts Register. Concerns are reported on F-AB1 Bribery Concerns Report and assessed on F-AB2 Bribery Concerns Assessment, with committee work recorded on F-AB5 Focus ABC Committee.

Using the Policy

Edit the procedure to match your business, such as the spending limits, the anti-bribery lead and committee arrangements, the risk rating thresholds and the reporting route for concerns. Name the person in the Controlled By field, give it top level approval and brief all workers.

Related Documents

The public statement sits in P-10 Anti Bribery and Corruption Policy, with gifts covered by P-108 Hospitality and Gifts Policy and reporting protected under P-14 Whistleblowing Policy. GG-1-18 Anti-Bribery and Corruption Guidance and TT-1-18 Anti-Bribery and Corruption Training Talk support the awareness training the procedure requires.