Anti-Bribery and Corruption Policy Template

This Anti-Bribery and Corruption Policy (“Policy”) applies to all employees, officers, directors, contractors, and third-party representatives (“Personnel”) of [Company Name].

1. Purpose

The purpose of this Policy is to set out [Company Name]’s zero-tolerance stance toward bribery and corruption and to ensure compliance with applicable laws, including the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and relevant local regulations.

2. Prohibited Practices

Personnel must not:

• Offer, give, solicit, or accept bribes, kickbacks, or facilitation payments.

• Provide or accept gifts or hospitality intended to improperly influence decisions.

• Use company funds or assets for unlawful purposes.

3. Gifts and Hospitality

Reasonable and proportionate gifts or hospitality may be permitted if they are:

• Not intended to gain improper business advantage.

• Consistent with local laws and company policy.

• Fully disclosed and recorded in accordance with company procedures.

4. Third-Party Dealings

• Third-party vendors, consultants, and agents must undergo due diligence checks.

• Contracts with third parties shall include anti-bribery compliance clauses.

• The Company reserves the right to audit and monitor third-party compliance.

5. Responsibilities of Personnel

• All employees must complete mandatory anti-bribery training.

• Employees are required to report any suspected violations immediately.

• Failure to comply may result in disciplinary action, including termination.

6. Reporting and Investigations

• Reports can be made confidentially via [Company hotline/email].

• The Company prohibits retaliation against individuals who report violations in good faith.

• Investigations will be conducted promptly and fairly.

7. Disciplinary Action

Employees or third parties found violating this Policy may face termination, contract cancellation, legal proceedings, and liability for damages.

8. Review and Updates

This Policy shall be reviewed annually and updated as necessary to reflect changes in law or business operations.

Acknowledgment

All Personnel must acknowledge in writing that they have read, understood, and agreed to comply with this Policy.