Is an anti-bribery policy required by law in the EU?

Yes for some entities. The French Loi Sapin 2 requires firms over 500 employees and €100m turnover to implement an eight-pillar corruption-prevention program. The Italian D.Lgs. 231/2001 effectively requires an Organisational Model that addresses bribery for all entities exposed to enforcement. UK Bribery Act section 7 imposes a strict-liability corporate offence; the only defence is 'adequate procedures'. Outside these, an ABC policy is best practice and a procurement expectation.

Does the policy align with ISO 37001?

Yes. ISO 37001:2016 sets the international standard for anti-bribery management systems. The eight clauses of ISO 37001 (context, leadership, planning, support, operation, performance, improvement, with anti-bribery clauses on risk assessment, due diligence, financial controls, raising concerns, and investigations) are reflected in the template structure.

How are gift and hospitality thresholds set?

The thresholds in section 6 are illustrative. Set them in absolute amounts that reflect the local cost of living and the sensitivity of your sector. Public-sector-adjacent firms typically use €50/€100/€250; firms with no public-sector exposure use higher thresholds. Document the rationale.

Free template · Updated May 2026

Anti-Bribery and Corruption Policy

A complete anti-bribery and corruption policy aligned with ISO 37001:2016, the UK Bribery Act 2010 adequate-procedures guidance, and the French Loi Sapin 2 eight pillars. Includes gifts and hospitality thresholds, third-party due diligence, facilitation-payment rules, and the reporting route.

1. Statement of commitment

[Organisation] has zero tolerance for bribery and corruption. We do not offer, give, request, or accept bribes, kickbacks, or other improper payments or advantages of any kind, anywhere in the world. This commitment applies to all persons acting on behalf of [Organisation], including employees, officers, directors, agents, consultants, and suppliers.

2. Scope

This Policy applies to [Organisation], all subsidiaries it controls, all employees and contractors, and to third parties acting on its behalf. It applies regardless of jurisdiction; where local law is stricter than this Policy, local law applies.

3. Definitions

Bribery: offering, giving, requesting, or accepting anything of value to influence the act or decision of another, where the influence is improper.
Public official: any person exercising governmental authority, including officials of government departments, public agencies, state-owned enterprises, international organisations, and political parties or candidates.
Facilitation payment: a small payment to a government official to expedite a routine government action to which the payer is already entitled. Prohibited under this Policy.
Anything of value: cash and cash equivalents, gifts, hospitality, travel, entertainment, charitable donations, political contributions, employment offers, services, discounts not generally available.

4. Prohibited conduct

Offering, giving, promising, requesting, or accepting bribes, in any form.
Making facilitation payments to public officials.
Using third parties (agents, distributors, consultants, joint-venture partners) to do indirectly what this Policy prohibits directly.
Making political contributions on behalf of [Organisation] without prior approval of the Board.
Making charitable donations that are conditioned, expressly or implicitly, on a business benefit.
Falsifying books and records to conceal payments or to misrepresent transactions.
Retaliating against a person who refuses to pay or accept a bribe, reports a suspicion, or cooperates in an investigation.

5. Gifts and hospitality

Gifts and hospitality are permitted only where modest, occasional, transparent, consistent with local custom, and not in connection with a specific business decision. The following thresholds apply:

Category	Per-event threshold	Pre-approval required
Gift offered or received from a private-sector counterparty	€100	Above €100: Head of Compliance
Hospitality offered or received from a private-sector counterparty	€250 per person	Above €250: Head of Compliance
Gift offered to or received from a public official	€0 (prohibited)	All exceptions: General Counsel + Board
Hospitality offered to or received from a public official	€50 per person, only at official events	Above €50: General Counsel
Travel for a public official	Prohibited	n/a

All gifts and hospitality above €50 are recorded in the gifts register, regardless of whether pre-approval was required. The register is reviewed quarterly by Internal Audit.

6. Third-party due diligence

Before engaging an agent, distributor, consultant, or joint-venture partner, [Organisation] conducts due diligence proportionate to the bribery risk. Tiers:

Tier 1 (low risk): screening against sanctions and PEP lists; declaration of beneficial ownership.
Tier 2 (medium risk): Tier 1 plus reference checks, review of adverse media, completion of an ABC questionnaire.
Tier 3 (high risk): Tier 2 plus on-site or third-party investigation, financial-statement review, ongoing monitoring with annual refresh.

Risk tier is determined by country (Transparency International CPI), sector, counterparty type (agent / consultant interfacing with public officials = automatic Tier 3), and transaction value. The tiering decision is documented and reviewed before contract execution.

7. Contractual safeguards

Contracts with agents and consultants include:

An anti-bribery warranty.
A right to audit books and records on reasonable notice.
Termination rights for material breach of ABC obligations.
A prohibition on subcontracting without consent.
A reporting obligation for ABC concerns through the [Organisation] channel at [URL].

8. Books and records

All transactions are recorded accurately and in reasonable detail. No off-the- books account, no false or misleading entry, no payment authorised on the understanding that it will be used otherwise than as described. Finance reviews flagged transactions monthly.

9. Reporting concerns

Any person who suspects bribery or corruption should report it through [Organisation]'s whistleblowing channel at [URL]. Reports may be anonymous. Reporters are protected from retaliation under [Organisation]'s Anti-Retaliation Policy and applicable law. Refusing to pay or accept a bribe is never grounds for adverse consequences; it is expected conduct.

10. Training

Annual mandatory ABC training for all employees. Additional role-based training for finance, procurement, sales, and any function exposed to public-sector counterparties. Records of completion held in the LMS.

11. Sanctions for breach

Substantiated breaches of this Policy result in disciplinary action up to and including termination of employment. Suppliers and agents found to be in breach face contract termination, debarment from future engagement, and referral to authorities where appropriate. Officers and directors who authorise or condone breaches face the same consequences.

12. Governance

The Head of Compliance owns this Policy. The Board's Audit Committee reviews ABC programme effectiveness quarterly. Internal Audit conducts an annual review of gifts register, third-party due diligence files, and a sample of high-risk transactions.

13. Review

This Policy is reviewed at least annually and after any material event (significant enforcement action, change in laws, organisational restructure).

Adopted by [Organisation], date [yyyy-mm-dd]. Signed by the Chair of the Board. Communicated to all in scope via the standard policy distribution route. Next review: [yyyy-mm-dd].