Anti-bribery—adequate procedures
Anti-bribery—adequate procedures

The following Risk & Compliance guidance note provides comprehensive and up to date legal information covering:

  • Anti-bribery—adequate procedures
  • Regulatory requirements
  • Assessing the risk of bribery
  • Who is responsible for anti-bribery procedures?
  • Key features of an anti-bribery policy
  • Implementing your anti-bribery and corruption policy
  • Monitoring and reviewing your anti-bribery and corruption procedures

It is an offence to pay or receive a bribe under the Bribery Act 2010 (BA 2010). Companies and partnerships will also commit an offence where a bribe is paid on their behalf. For further information, see Practice Notes: The Bribery Act 2010—an introductory guide and Failing to prevent bribery.

It is a defence to have adequate procedures in place to prevent bribery.

This Practice Note explains how to put such procedures in place.

Regulatory requirements

The Law

The law relating to bribery and corruption is found in BA 2010 (see: The Bribery Act 2010—an introductory guide).


The Ministry of Justice (MoJ) has issued guidance on adequate procedures, as it is required to do under the BA 2010.

The guidance is intended to help organisations understand the types of procedures they can put in place to prevent bribery. It is formulated around six guiding principles, each followed by commentary and examples.

The guidance is not prescriptive and departures from the suggested procedures contained in the guidance will not of themselves give rise to a presumption that an organisation does not have adequate procedures.

BS 10500 is a management system standard developed in response to the UK Bribery Act 2010 for which you can be independently certified by a third party such as the BSI Group (also known as the British Standards Institution—the national standards body