Glossary
Anti-Bribery (ABC)
The body of law, controls, and culture aimed at preventing the offering or accepting of bribes in commercial activity. A mature ABC programme combines statutory prohibitions (FCPA, UK Bribery Act), the ISO 37001 management standard, and internal controls including third-party due diligence and a whistleblower channel routing ABC concerns to a dedicated owner.
Full definition
Anti-bribery (often paired as 'anti-bribery and corruption', ABC) is a cross-cutting compliance discipline that combines statutory prohibitions (FCPA, UK Bribery Act, OECD Anti-Bribery Convention domestic implementations), management-system standards (ISO 37001), and internal controls. A mature ABC programme has: a board-approved policy, a risk assessment, third-party due diligence (typically tiered by spend and country risk), gifts and hospitality rules with monetary thresholds, training, monitoring (transaction testing), and a whistleblower channel that explicitly accepts ABC concerns. Whistleblower reports are the single largest source of FCPA enforcement actions in the US; the same pattern holds in UK, Germany, France, and Italy bribery enforcement. Confidly is designed to make ABC concerns routable to a dedicated ABC owner separate from the general HR/ethics queue, because regulators prefer evidence that the channel was structurally capable of escalating bribery concerns.
Related terms
- UK Bribery Act 2010 The UK's extraterritorial anti-bribery statute, with a strict-liability corporate offence for failure to prevent bribery (section 7). The offence applies to commercial organisations carrying on business in the UK regardless of where bribery takes place. The only defence is adequate procedures. A functioning whistleblower channel is treated as a strong indicator of adequate procedures.
- FCPA The US Foreign Corrupt Practices Act of 1977 has two prongs: anti-bribery (it is unlawful to pay foreign officials to obtain or retain business) and accounting (issuers must keep accurate books and maintain internal accounting controls). Enforced by the DOJ and SEC, with settlements running from tens of millions to billions. EU multinationals with US listings comply.
- ISO 37001 The international standard for anti-bribery management systems, published by ISO in 2016. ISO 37001 specifies requirements for an anti-bribery management system with a documented policy, due diligence on third parties, training, and a 'raise concerns' procedure that maps directly to a whistleblowing channel. An effective whistleblowing channel is widely treated as a prerequisite for certification.