Compliance guide
Anti-Bribery and Corruption (ABC) Policy Template
An anti-bribery and corruption (ABC) policy sets out your zero-tolerance stance on bribery and corruption and the rules your people must follow. Whether it's called an anti-bribery, anti-corruption or anti-bribery & corruption policy, it's the same document, and this guide gives you a free template, sample wording, and a path to a portal-ready version.
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Key takeaways
- An ABC policy states your zero-tolerance position on bribery and corruption, defines what's prohibited, and sets rules for gifts, hospitality and third parties.
- Anti-bribery, anti-corruption and anti-bribery & corruption (ABC) policy all refer to the same document.
- It's a common requirement for supplier prequalification, tenders and procurement onboarding (Felix, Avetta, CM3 and similar).
- Key frameworks include the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA) and the ISO 37001 anti-bribery management standard.
- Write your own from the template below, or have a tailored, portal-ready document done for you.
What is an anti-bribery and corruption policy?
An anti-bribery and corruption policy is an internal document that sets out your business's commitment to acting ethically, prohibits bribery and corruption in all its forms, and tells your people what they can and can't do, covering gifts, hospitality, facilitation payments, donations and dealings with third parties.
"Bribery" means offering, giving, receiving or soliciting something of value to improperly influence a decision. "Corruption" is the broader abuse of entrusted power for private gain. A good policy addresses both, which is why it's often labelled an ABC policy.
The laws and standards behind an ABC policy
Which law applies depends on where you operate and who you deal with, but most policies reference one or more of these:
- UK Bribery Act 2010, one of the strictest regimes; it includes a corporate offence of failing to prevent bribery and applies across borders. Facilitation payments are not permitted.
- US Foreign Corrupt Practices Act (FCPA), prohibits bribing foreign officials and sets accounting and record-keeping requirements; it reaches many non-US businesses.
- ISO 37001, the international standard for anti-bribery management systems; you can align to it without being certified.
- Local anti-corruption and criminal laws, most countries prohibit bribery of public officials and, increasingly, private (commercial) bribery.
Who needs an anti-bribery and corruption policy?
Two situations make one important:
- Prequalification and procurement, larger customers and supplier portals routinely ask vendors for an ABC policy before onboarding, regardless of size.
- Legal and reputational risk, a documented policy, communicated and followed, is a key part of the "adequate procedures" defence under the UK Bribery Act and good practice everywhere.
Charities, companies and sole traders are all asked for one. A short, genuine policy that fits your business is more credible than a long generic copy.
What to include: ABC policy template structure
Adapt this outline. Keep it clear and practical so every worker can follow it:
- Purpose and scope, why the policy exists and who it applies to (staff, contractors, agents, suppliers).
- Policy statement, a clear zero-tolerance commitment to bribery and corruption.
- Definitions, bribery, corruption, facilitation payments and what "something of value" means.
- What's prohibited, bribes, kickbacks, facilitation payments and improper inducements, given or received.
- Gifts and hospitality, what's acceptable, any value thresholds, and when to seek approval or register it.
- Donations and sponsorship, rules for political and charitable donations.
- Third parties, due diligence on agents, intermediaries and suppliers who act on your behalf.
- Responsibilities, who owns the policy and who to ask for guidance.
- Record keeping, how gifts, hospitality and payments are recorded.
- Raising concerns, how staff can report suspected bribery safely (whistleblowing) without retaliation.
- Breaches, the consequences of non-compliance.
- Training and review, how people are trained and how often the policy is reviewed.
- Approval, signed and dated by a director or senior manager.
Sample policy statement
Download the editable ABC policy template
Pop in your email and we'll send the full ABC policy template in Word and PDF, ready to brand, adjust and sign.
How to write and roll out your ABC policy
A policy only works if people know about it and follow it.
- 1
State your commitment
Open with a clear zero-tolerance position on bribery and corruption that applies to everyone acting for the business.
- 2
Set the rules that bite
Be specific on gifts, hospitality and facilitation payments, including thresholds and when approval or registration is required.
- 3
Address third parties
Describe how you check agents, intermediaries and suppliers, since you can be exposed by their conduct.
- 4
Give people a reporting channel
Provide a safe, clear way to raise concerns without fear of retaliation.
- 5
Train and communicate
Share the policy at induction and refresh it periodically so people actually know the rules.
- 6
Approve and review
Have it signed and dated by senior management, then review at least annually and after any incident.
Free template vs done-for-you document
Happy to do the editing yourself? The template above covers it. Short on time, or facing a procurement deadline? A done-for-you version is tailored to your business, written to clear prequalification, and ready to upload.
| Free template | Done-for-you document | |
|---|---|---|
| Price | £0 | Fixed fee |
| Effort from you | Half a day of editing | A short intake form |
| Bribery Act / FCPA wording | You research and adapt it | Mapped to your markets |
| Gifts & hospitality thresholds | You set them | Drafted for you |
| Portal-ready PDF | Format it yourself | Supplied, signed-ready |
| If a buyer rejects it | You fix it | We revise it free |
Prefer your ABC policy done for you?
Tell us a bit about your business and we'll prepare a tailored, signed-ready ABC policy written to clear prequalification and formatted for portals like Felix, Avetta and CM3.
Requests for the anti-bribery and corruption policy are reviewed and prepared manually, we'll follow up by email.