Key risk areas—bribery and corruption

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

  • Key risk areas—bribery and corruption
  • Gifts and hospitality
  • Offences
  • Government guidance
  • Proportionality—setting a limit
  • Gift and hospitality policies and procedures
  • Agents and intermediaries
  • What is an agent or intermediary?
  • Application of the law to agents and intermediaries and the risks they present
  • Adequate procedures
  • More...

Key risk areas—bribery and corruption

The Ministry of Justice (MoJ) issued guidance which is formulated around six guiding principles. These principles, particularly principle 3, make it clear that you should adopt a risk-based approach to managing bribery risks. Adequate anti-bribery procedures should be proportionate to the bribery risks you face. In order to do this, you will need to identify those risks. You should therefore perform a risk assessment across your business as a first step (see Precedent: Bribery and corruption—risk assessment).

To a certain extent the level of risk you face will be linked to the:

  1. size of your organisation

  2. type and nature of the persons associated with it, and

  3. nature and complexity of your business

This Practice Note explains common risk areas you should consider. They include:

  1. gifts and hospitality

  2. agents and intermediaries

  3. commissions

  4. facilitation payments

  5. joint ventures and acquisitions

  6. charitable and political donations

Gifts and hospitality

Subtopic: Gifts and hospitality provides guidance on the bribery risks associated with gifts and hospitality and what adequate procedures might look like, and contains various related Precedents. See Practice Note: Anti-bribery and corruption—gifts and hospitality.


The potential offences that can be committed in the provision of gifts and/or hospitality are:

  1. bribing another person (Bribery Act 2010 (BA 2010))

  2. bribing a foreign public official (BA 2010, s 6)

  3. as a corporate body, failing to prevent bribery (BA 2010, s 7)

Government guidance


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