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The UK Bribery Act 2010 creates criminal liability for the Company if an employee or agent pays a bribe — even without the Company's knowledge — unless adequate procedures are in place. This policy constitutes those procedures.
Covers: the six prohibited acts, the UK Bribery Act s.7 adequate procedures defence, facilitation payments prohibition (with explicit naming and the reason it applies globally), a gifts and hospitality traffic-light table (acceptable/conditional/prohibited) with threshold guidance, the gifts register requirement, third-party due diligence checklist, and reporting obligations. Jurisdiction flags for IE (Criminal Justice (Corruption Offences) Act 2018), UK (Bribery Act 2010), US (FCPA), CA (CFPOA), and AU (Criminal Code Act 1995).
FAQS
Q Does the UK Bribery Act apply to companies not based in the UK?
Yes — and this is one of the most significant aspects of the Act. The section 7 corporate offence (failure to prevent bribery) applies to any company that carries on business or any part of its business in the UK, regardless of where it is incorporated or where the bribery occurred. An Irish, US, Canadian, or Australian company with UK employees, UK customers, or UK commercial activity is subject to the Act. The only defence is having adequate anti-bribery procedures in place. This policy constitutes those procedures.
Q What are facilitation payments and why are they prohibited?
A facilitation payment is a small unofficial payment to a government official to speed up a routine government action — expediting a licence, clearing customs, securing a utility connection. They are prohibited by this policy in all jurisdictions and all circumstances, including where they are customary in a particular country. They are a criminal offence under the UK Bribery Act and are broadly prohibited across all five jurisdictions covered by this suite.
Q What should an employee do if they are offered a bribe?
Refuse it. Note the offer in writing immediately — what was offered, by whom, in what context, and on what date. Report it to the legal function and their manager without delay. Do not attempt to investigate or negotiate. The policy is explicit: no employee will be penalized for refusing to pay or accept a bribe, even where the refusal results in the loss of a business opportunity.
Q What is the gifts register and who maintains it?
The gifts register records all gifts and hospitality given or received above the stated minimum threshold, within five business days. It must capture: date, description, estimated value, giver/recipient, business context, and whether approval was obtained. It is maintained by Finance, Legal, or Compliance (as appropriate) and reviewed by senior leadership quarterly. The policy requires the register to be maintained but does not provide its format — this is typically a shared spreadsheet or a field in the compliance management system.
The UK Bribery Act 2010 creates criminal liability for the Company if an employee or agent pays a bribe — even without the Company's knowledge — unless adequate procedures are in place. This policy constitutes those procedures.
Covers: the six prohibited acts, the UK Bribery Act s.7 adequate procedures defence, facilitation payments prohibition (with explicit naming and the reason it applies globally), a gifts and hospitality traffic-light table (acceptable/conditional/prohibited) with threshold guidance, the gifts register requirement, third-party due diligence checklist, and reporting obligations. Jurisdiction flags for IE (Criminal Justice (Corruption Offences) Act 2018), UK (Bribery Act 2010), US (FCPA), CA (CFPOA), and AU (Criminal Code Act 1995).
FAQS
Q Does the UK Bribery Act apply to companies not based in the UK?
Yes — and this is one of the most significant aspects of the Act. The section 7 corporate offence (failure to prevent bribery) applies to any company that carries on business or any part of its business in the UK, regardless of where it is incorporated or where the bribery occurred. An Irish, US, Canadian, or Australian company with UK employees, UK customers, or UK commercial activity is subject to the Act. The only defence is having adequate anti-bribery procedures in place. This policy constitutes those procedures.
Q What are facilitation payments and why are they prohibited?
A facilitation payment is a small unofficial payment to a government official to speed up a routine government action — expediting a licence, clearing customs, securing a utility connection. They are prohibited by this policy in all jurisdictions and all circumstances, including where they are customary in a particular country. They are a criminal offence under the UK Bribery Act and are broadly prohibited across all five jurisdictions covered by this suite.
Q What should an employee do if they are offered a bribe?
Refuse it. Note the offer in writing immediately — what was offered, by whom, in what context, and on what date. Report it to the legal function and their manager without delay. Do not attempt to investigate or negotiate. The policy is explicit: no employee will be penalized for refusing to pay or accept a bribe, even where the refusal results in the loss of a business opportunity.
Q What is the gifts register and who maintains it?
The gifts register records all gifts and hospitality given or received above the stated minimum threshold, within five business days. It must capture: date, description, estimated value, giver/recipient, business context, and whether approval was obtained. It is maintained by Finance, Legal, or Compliance (as appropriate) and reviewed by senior leadership quarterly. The policy requires the register to be maintained but does not provide its format — this is typically a shared spreadsheet or a field in the compliance management system.
