Anti-Bribery Policy

As a registered charity, [Charity name] is committed to conducting all of its activities with integrity, transparency, and the highest ethical standards.
The Charity adopts a zero-tolerance approach to bribery and corruption and is committed to complying with all applicable laws, including the Bribery Act 2010.

This Anti-Bribery Policy sets out the responsibilities of the Charity, its Trustees, employees, volunteers, and representatives in preventing, detecting, and responding to bribery and corruption in any form.

Purpose of the Policy

1.1 The purpose of this Policy is to:

Prevent bribery and corruption in all areas of the Charity’s work.
Ensure compliance with the Bribery Act 2010 and related legislation.
Protect the Charity’s reputation, assets, and public trust.
Provide clear guidance on expected standards of conduct.

1.2 This Policy supports Trustees in fulfilling their legal and fiduciary duties and promotes an ethical culture across the Charity.

Scope of the Policy

2.1 This Policy applies to:

All Trustees, employees, volunteers, and interns.
Contractors, consultants, agents, partners, and third parties acting on behalf of the Charity.

2.2 The Policy applies to all activities of the Charity, whether carried out in the UK or overseas.

Definition of Bribery and Corruption

3.1 Bribery is defined as:

Offering, promising, giving, requesting, or accepting any financial or other advantage to induce or reward improper performance of a function or activity.

3.2 Corruption includes the misuse of entrusted power for private gain.

3.3 A bribe may take many forms, including:

Cash payments or gifts.
Hospitality, travel, or entertainment.
Discounts, loans, or favours.
Donations or sponsorships offered to influence decisions.

Policy Statement

4.1 [Charity name] prohibits:

Giving or offering bribes.
Requesting or accepting bribes.
Facilitating bribery by third parties.
Turning a blind eye to suspected bribery.

4.2 No individual associated with the Charity may engage in bribery, regardless of local customs, business practices, or perceived pressure.

Gifts, Hospitality, and Expenses

5.1 Gifts and hospitality must:

Be reasonable, proportionate, and infrequent.
Be given or received for legitimate purposes only.
Not influence, or appear to influence, decision-making.

5.2 The following are strictly prohibited:

Cash or cash-equivalent gifts.
Gifts or hospitality intended to secure improper advantage.
Gifts offered during sensitive decision-making processes.

5.3 All gifts and hospitality must be:

Declared in accordance with the Charity’s internal procedures.
Approved where required.

Facilitation Payments

6.1 Facilitation payments are unofficial payments made to secure routine governmental actions.

6.2 [Charity name] strictly prohibits facilitation payments of any kind.

6.3 Where an individual is faced with an immediate threat to personal safety, any payment made must be:

Reported immediately to senior management or the Trustees.
Fully documented with reasons recorded.

Third-Party Relationships

7.1 The Charity may be held liable for bribery committed by third parties acting on its behalf.

7.2 Appropriate due diligence will be conducted on:

Contractors and suppliers.
Agents and intermediaries.
Overseas partners.

7.3 Contracts with third parties may include anti-bribery clauses where appropriate.

Charitable Donations and Sponsorship

8.1 Charitable donations made or received must not be used as a means to conceal bribery.

8.2 All donations and sponsorship arrangements must:

Be transparent and properly recorded.
Comply with the Charity’s Gift Acceptance and Donation Policy.

Responsibilities

9.1 The Board of Trustees is responsible for:

Approving and overseeing this Policy.
Ensuring effective anti-bribery controls are in place.

9.2 Senior management is responsible for:

Implementing this Policy.
Promoting awareness and compliance.

9.3 All individuals covered by this Policy are responsible for:

Acting honestly and ethically.
Familiarising themselves with this Policy.
Reporting suspected breaches.

Reporting Concerns

10.1 Anyone who suspects bribery or corruption must report it promptly.

10.2 Reports may be made:

To a line manager or senior officer.
Directly to the Trustees.
Through the Charity’s Whistleblowing arrangements (where applicable).

10.3 The Charity will:

Treat all reports seriously and confidentially.
Protect individuals who raise concerns in good faith.

Investigation and Breaches

11.1 All reported concerns will be investigated promptly and fairly.

11.2 Breaches of this Policy may result in:

Disciplinary action.
Termination of engagement.
Reporting to law enforcement or regulators.

Training and Awareness

12.1 The Charity will:

Provide appropriate anti-bribery training where necessary.
Communicate this Policy to relevant individuals.

12.2 Awareness of this Policy forms part of the Charity’s commitment to ethical conduct.

Monitoring and Review

13.1 Compliance with this Policy will be monitored regularly.

13.2 This Policy will be reviewed:

At least annually, or
Following changes in legislation or risk exposure.

Conclusion

By adhering to this Anti-Bribery Policy, [Charity name] ensures that it operates lawfully, ethically, and transparently, safeguarding its reputation, resources, and the trust placed in it by beneficiaries, donors, and the public.

Signed: ………………………………………
Chair of the Board of Trustees

Date: ………………………………………

Charity Policy templates

Accessibility Policy, Anti-Bribery Policy, Anti-Fraud and Corruption Policy, Anti-Harassment Policy, Board of Trustees Code of Conduct, Charitable Objectives Policy, Child Protection Policy, Code of Conduct for Employees and Volunteers, Community Development Policy, Community Engagement Policy, Complaints Handling Policy, Confidentiality Policy, Conflict of Interest Policy, Conflict Resolution Policy, Crisis Management Policy, Cultural Competence Policy, Data Protection and Privacy Policy, Digital Inclusion Policy, Emergency Preparedness Policy, Environmental and Sustainability Policy, Equality and Diversity Policy, Ethical Fundraising Policy, Exit Policy, Expenses Policy, Feedback and Evaluation Policy, Feedback Mechanism Policy, Financial Controls Policy, Foreign Receipts and Payments Policy, Fundraising Policy, Gift Acceptance and Donation Policy, Governance and Accountability Policy, Grant-Making Policy, Health and Safety Policy, Incident Reporting Policy, Information Sharing Policy, Intellectual Property Policy, Investment Policy, IT and Cybersecurity Policy, Learning and Development Policy, Media and Public Relations Policy, Membership Policy, Mentoring and Coaching Policy, Online Safety Policy, Partnership and Collaboration Policy, Peer Support Policy, Privacy Impact Assessment Policy, Procurement and Supplier Management Policy, Public Benefit Policy, Records Retention Policy, Remuneration and Compensation Policy, Reserves Policy, Risk Management Policy, Safeguarding Vulnerable Beneficiaries Policy, Service Delivery Policy, Social Media and Communications Policy, Social Responsibility Policy, Succession Planning Policy, Technology Use Policy, Transparency and Accountability Policy, Travel and Subsistence Policy, Volunteer Induction and Training Policy, Volunteer Management Policy, Volunteer Rights and Responsibilities Policy, Whistleblowing Policy

Disclaimer:

Naail & Co provides these policy templates solely as guidelines or standard templates to assist charities in developing their own policies in accordance with Charity Commission England & Wales compliance. These templates are not intended to serve as legal or professional advice, and Naail & Co cannot be held responsible or liable for any outcomes arising from their use. It is essential that each registered charity carefully tailors and customizes these policies to reflect its specific needs, structure, and legal obligations. We strongly recommend that charities seek independent legal or professional advice to ensure compliance with all relevant laws and regulations.

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