Anti-bribery and corruption—staff communication, training and awareness
Anti-bribery and corruption—staff communication, training and awareness

The following Practice Compliance practice note provides comprehensive and up to date legal information covering:

  • Anti-bribery and corruption—staff communication, training and awareness
  • Top-level commitment
  • Communicating policies and procedures
  • Internal communication
  • External communication
  • Training and awareness

MoJ guidance on the procedures commercial organisations should put in place to prevent bribery is crafted around six principles. The principles are not prescriptive; they are intended to be flexible and outcome focussed.

Bribery prevention procedures should be proportionate to risk of bribery faced by the organisation. It follows that the procedures put in place to implement an organisation’s bribery prevention policies should be designed to:

  1. mitigate identified risks, and

  2. prevent deliberate unethical conduct on the part of associated persons

An important aspect of those procedures is the communication of your policies and procedures to staff (of all levels), and training in their application. This is reinforced by MoJ principle 5—Communication (including training).

This Practice Note discusses some of the ways you can train staff and raise awareness about anti-bribery and corruption issues.

Top-level commitment

One of the key messages running through Government guidance on anti-bribery and corruption procedures is top-level commitment.

Effective leadership in bribery prevention will take a variety of forms appropriate for and proportionate to the organisation’s size, management structure and circumstances. But whatever the model, top-level commitment is likely to inclu

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