What is an Anti-Bribery and Corruption Policy?

An Anti-Bribery and Corruption Policy (or “ABC Policy”) describes the standards and processes that a company puts in place to address key risks related to bribery and corrupt practices, such as unethical transactions, money laundering and improper gifts and entertainment. Please remember that it is not enough to adopt a policy - policies like these should also be clearly communicated and made available to all staff. The policy should be regularly reviewed to reflect changes to internal operations, regulations, and the business environment - this is particularly important for young companies and startups that tend to grow and evolve quickly over time.

How should I use the template?

This template presents a core structure alongside anti-bribery and corruption topics that are relevant to most companies. Each section offers specific instructions on what companies should include per topic and lists policy language they can adapt. The template addresses topics such as:

• Screening for politically exposed persons (PEPs)
• Gifts and entertainment
• Charitable and political contributions
• Hiring independence
• Employee training and compliance
• Internal and external communications and audits
• Procurement and distribution processes
• Reporting financial irregularities

Note that the template is merely a starting point! Some topics may be more relevant to you than others, and if you are operating in high-risk sectors, you may want to apply more robust standards. Use the template as a basis on which to make changes to match your own unique characteristics and structures, as well as language and style.