Your compliance roadmap for bribery prevention
Welcome to your first step towards anti-bribery compliance. Follow this page to understand the key factors in navigating the UK Bribery Act 2010, one of the toughest anti-corruption laws worldwide.
The UK Bribery Act 2010 is an anti-corruption law used in the UK, and it serves as inspiration for similar legislation in other countries.
Although the US Foreign Corrupt Practices Act (FCPA) is older and often used to combat corporate malpractice, the UK Bribery Act is more comprehensive. It outlaws giving or taking bribes under any circumstance, including grease or facilitation payments.
Individuals and companies convicted of breaching this law anywhere in the world can be penalised with unlimited fines and up to 10 years in prison.
If you have a bribery prevention roadmap and need support implementing it, we can help. If your business has over 50 employees, register for a free demo to learn how we can support you.
Tackling corporate bribery
The Bribery Act includes a ‘strict liability’ offence for UK companies that fail to prevent bribery by employees, agents, subsidiaries, or other ‘associated persons.’
So, what does this mean? Strict liability means that if an associated person offers or pays a bribe on your company’s behalf, you can face unlimited fines even if your company didn’t sanction the bribe or wasn’t aware of it being paid.
In an instance such as this, the only defence available is that your company had implemented the ‘adequate procedures’ to prevent bribery.
For this reason alone, policy attestation, staff training, supply chain due diligence, and an effective whistleblowing channel are vital.
Preparing anti-bribery policies and procedures, ensuring they’re attested to by employees and associated persons. Depending on your risk assessment, these may include gifts and hospitality, donations, charitable contributions, facilitation payments, and dealing with public officials.
Training your employees and associated persons to identify, avoid, resist, and report bribery. This training should include practical scenarios that are relevant to your business.
Implementing a Gifts and Hospitality Register (GHR) to address the most common channel for actual and perceived bribery cases.
Offering an anonymous whistleblowing register that your staff can use to report suspicions of internal or external wrongdoing.
Obtaining compliance declarations from third-party associated persons to ensure your supply chain is aligned with your internal anti-bribery standards.
Conducting anonymous staff surveys to uncover deficiencies in your internal controls and external threats, which should inform the continuous improvement of your anti-bribery policies and procedures.
Corporate policies are the backbone of successful compliance. They guide conduct and behaviour and set out the types of behaviour a firm expects from its employees.
They help to translate external regulatory requirements into a company’s DNA, ensuring compliance is achieved through employee understanding.
With our online Policy Hub, your employees can review and attest to all relevant policies, and you can provide evidence of policies to regulators and authorities when required.
Head to our Policy Hub page to read about our complete, cost-effective policy management solution.
Anti-bribery training
Most UK businesses have anti-bribery policies. However, it’s how these policies are implemented that makes the difference.
Your staff must understand your company’s rules and expectations in relation to gifts, hospitality, donations, and sponsorships. Those in higher-risk positions may require further training on issues specific to your company.
The UK government’s Bribery Act guidance refers to ‘effective training that’s continuous, and regularly monitored and evaluated,’ but repeated training can often lead to employee fatigue.
That’s why we provide a range of anti-bribery courses to keep staff aware and engaged.
Learn about Compliance Essentials
Compliance Essentials is our most popular training library, consisting of 30 off-the-shelf courses and microlearning. Jump into over 100 essential e-learning and microlearning modules and benefit from refresher courses for more experienced staff. Plus, you’ll have the option to host the Essentials Library on our Learning Management System — or use your own.
Gifts and hospitality registers
Gifts and hospitality are widely recognised as high risk for bribery. They can be used as outright bribes on their own or as a way of obliging or entrapping a person.
Following the UK government’s advice, you should establish policies that clearly outline your company’s rules, limits, and procedures.
Depending on the nature of your business and risk assessment, you may want to use a Gifts and Hospitality Register (GHR) to record and approve staff requests for gifts, hospitality, sponsorships, and more.
With our online Gifts and Hospitality Register, you can track and analyse your data over time to ensure compliance with the Bribery Act.
Whistleblowing
Blowing the whistle on internal and external malpractice is essential for companies.
Whistleblowing is the process of employees reporting suspected or actual misconduct. It’s done in confidence or anonymously to ensure staff don’t feel unsafe when reporting such behaviour.
A solution can be to create an online whistleblowing register, enabling employees to report any suspicion or knowledge of bribery anonymously.
Third-party due diligence
You’ll likely need third parties to complete disclosures or declarations regarding compliance with bribery laws, regulations, or internal standards.
However, using paper-based processes is slow and inefficient, and can lead to unnecessary duplication, omission, or error.
Using our online compliance declarations helps you streamline the collection, analysis, and management of due diligence for associated persons outside your organisation.
Staff surveys
Your employees and managers are your first line of defence against bribery risks.
Principle 3 of the UK Government's Bribery Act Guidance requires companies to assess bribery risks. Such surveys can uncover: "(i) deficiencies in employee training, skills and knowledge, (ii) incentives for excessive risk-taking, (iii) lack of clarity in policies/procedures for gifts, hospitality charitable etc, (iv) lack of clear financial controls.”
Principle 6 reiterates that "staff surveys and questionnaires provide an important source of information on the effectiveness and a means by which employees and other associated persons can inform the continuing improvement of anti-bribery policies.”
Our Compliance Survey Tool helps you conduct robust, anonymous staff surveys that ensure the widest coverage and enable employees to provide feedback to you in confidence.
Bribery and corruption best practices
Here are some best practices for you to follow to ensure your company protects itself against bribery.
Six red flags for workplace bribery and corruption
Every year, trillions of dollars are lost through bribery and corruption — half of which is perpetrated by employees and contractors — so how can you spot it?
Discover the bribery red flags
10 ways to reduce the risk of bribery and corruption
Corruption affects all countries, rich and poor. It causes instability, inequality and poverty, and erodes national wealth. What can you do to reduce the risk in your company?
Eight tips for your gifts and hospitality policy
You need better oversight to avoid conflicts of interest that could undermine your organisation's reputation. We have eight tips to help make your life a little less complicated.
Experience the Skillcast difference with a free demo
See first-hand how we help you take control of compliance. By booking a demo, you can experience the Skillcast Portal, our courses and materials, and learn about your bespoke and customisation options. If you’re ready to book your demo with us, complete the form to the right of the page.
Our anti-bribery frequently asked questions
Bribery Prevention
Common FAQs
How can I monitor and manage anti-bribery compliance in my organisation?
How can I effectively distribute my anti-bribery policy to employees?
Are the courses SCORM-compliant?
What other tools are needed beyond training?
Can users only view the courses assigned to them?
Why Skillcast?
