Anti-Bribery and Corruption (ABC)

Corruption is a form of dishonesty or criminal activity undertaken by a person or organisation entrusted with a position of authority, in order to gain illicit advantages or unduly influence a business decision. It corrodes the fabric of society. It undermines people’s trust in political and economic systems, institutions and leaders. The cost for companies involved in corruption can be very high, both in terms of financial loss due to fines and in terms of reputational damage.

Corruption can take many forms and, therefore, there are many ways to challenge it. Bribery is a form of corruption: it is the practice of giving someone an unfair advantage in order to obtain an illicit gain as a result.

In most countries it is illegal to offer, promise, give, request, agree, receive or accept bribes. In the UK, this is enforced by the Bribery Act 2010. Including an anti-bribery statement is one element that can help protect your business, as according to the Act, you can be entitled to full defence if you can show you had ‘adequate procedures’ in place to prevent bribery – which includes ‘facilitation payments’. Other elements include top-level commitment, an appropriate risk assessment and due diligence, internal communications (including training), monitoring and review processes.

IBE Guidance

It is important that nobody in the organisation engages in any activity that might give the impression of corrupt intent. In this respect, developing the right approach to the giving and receiving of gifts and hospitality is key.
Think about the bribery and corruption risks you and your organisation might face. For example, you might want to do an assessment of the risks in the markets you operate in, and the people you deal with.
Conduct ethical due diligence. Knowing exactly who your partners and suppliers are can help to protect your organisation from working with people who might be less than trustworthy. You may want to ask a few questions and do a few checks before engaging others to represent you in business dealings (for more information see the section All you need to know about Ethical Due Diligence (EDD) included in this Toolkit).
The risks you face and the effectiveness of your procedures may change over time. Keep an eye on the anti-bribery and corruption steps you have taken so that they keep pace with any changes.
Small payments without a receipt are a risk. Facilitation payments - payments to induce anyone (particularly officials) to perform routine functions they are otherwise required to perform more quickly - are considered as bribes under the Bribery Act 2010. As such, they cannot be tolerated unless there is a real and imminent threat of safety to personal security.
The IBE’s free-to-use Say No Toolkit is a useful resource that provides practical support to people when they are faced with an ethical dilemma related to bribery or corruption. Share it with your colleagues and encourage them to use it.

Subject Matter Expert Resources

Transparency International is the global civil society organisation leading the fight against corruption. The UK Chapter, Transparency International UK, has created a free 30-minute online course Doing Business Without Bribery which provides comprehensive anti-corruption training for front-line staff.