How to draft an anti-bribery and corruption policy
Creating this policy ensures your business complies with the UK Bribery Act 2010 and builds the ethical foundation required by institutional investors.
The Bottom Line
To meet the legal requirements of the UK Bribery Act 2010, your business must have 'adequate procedures' in place to prevent bribery. Drafting a formal Anti-Bribery and Corruption (ABC) policy is the most effective way to document these procedures, protecting your company from liability for the actions of employees or partners and proving your reliability to potential investors during due diligence.
Why this policy matters
Under UK law, your company can be held criminally liable if a person associated with it (like an employee or agent) bribes someone to get or keep business. This is known as the 'corporate offence.' The only legal defence is showing that you had robust, clear policies in place to prevent such behaviour. Beyond legal protection, having this document ready is a standard 'tick-box' for any bank, partner, or investor looking to work with a professional fintech startup.
Steps to draft your policy
- Conduct a risk assessment: Think about where your business might be vulnerable. Do you deal with government officials? Do you work with third-party agents? Do you offer corporate hospitality? Identify the specific risks relevant to your niche.
- State a zero-tolerance approach: Your policy must start with a clear statement from the founders or board that the company prohibits all forms of bribery and corruption, including 'facilitation payments' (small payments to speed up a routine process).
- Define gifts and hospitality: Clearly outline what is acceptable. For example, you might set a specific limit (e.g., £50) for gifts and require that anything above this must be recorded in a 'Gifts and Hospitality Register.'
- Outline reporting procedures: Explain exactly how an employee can report a concern or a suspected bribe. This should link to your internal whistleblowing procedures, ensuring the reporter feels safe and protected.
- Include third-party conduct: State that your standards apply not just to staff, but to any consultants, suppliers, or partners acting on your behalf.
What to include in the document
A standard ABC policy should be easy to read and include the following sections:
| Section | What it covers |
|---|---|
| Policy Statement | A high-level commitment to the Bribery Act 2010. |
| Scope | Who the policy applies to (staff, contractors, etc.). |
| Prohibited Acts | Definitions of bribery, kickbacks, and facilitation payments. |
| Hospitality Rules | Rules for giving/receiving gifts and entertainment. |
| Record Keeping | Requirement for transparent financial records. |
Relatable Example
Example: If a software vendor offers you a free luxury weekend in Paris while you are deciding whether to use their platform, your ABC policy should provide the guidance to either decline the offer or ensure it is formally approved and recorded in a public register to avoid the appearance of a bribe.
Best Practices
- Keep it simple: Avoid dense legal jargon. Your team needs to understand the rules to follow them.
- Top-level commitment: Ensure the policy is signed or introduced by the CEO or Founders.
- Regular reviews: Set a date to review the policy annually to ensure it stays relevant as your business grows.
Created by hatch. • Updated on April 28, 2026