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Anti-Bribery Policy

An anti-bribery policy prohibits offering, giving, requesting or accepting bribes in any form — including facilitation payments to speed up government work — and sets rules for gifts and hospitality, dealings with public officials, donations, and due diligence on agents and vendors. It protects the company and its people from corruption risk under Indian law.

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[Company Logo][Company Name]

ANTI-BRIBERY & ANTI-CORRUPTION POLICY

Policy No.:: [Reference Number]
Version:: [Version Number]
Effective Date:: [Date]
Policy Owner:: [Compliance Officer]

1. Purpose

[Company Name] has zero tolerance for bribery and corruption. This policy sets out what is prohibited and the procedures that help us conduct business honestly and comply with the Prevention of Corruption Act, 1988 and other applicable laws.

2. Scope

It applies to directors, employees, and all third parties acting for the company, including agents, consultants, distributors, liaison firms and contractors.

3. Definitions

Bribe: anything of value offered, given, requested or accepted to improperly influence an action or decision.
Facilitation payment: a payment to a public servant to speed up a routine action.
Public official: any person holding a public office or working for a government body, PSU, regulator or public international organisation.
Anything of value: cash, gifts, travel, jobs, discounts, donations or favours.

4. Policy

No one may offer, give, request or accept a bribe, directly or through a third party.
Facilitation payments are prohibited. If a payment is demanded under threat to personal safety, ensure safety first and report immediately.
Gifts and hospitality must be modest, infrequent and not intended to influence. Gifts above ₹[Amount] given or received must be approved and recorded in the gift register.
No gifts or hospitality may be offered to public officials without prior written approval of the Compliance Officer.
Cash or cash-equivalent gifts are never permitted.
Donations and sponsorships require [Authorised Signatory] approval and must go to registered organisations with receipts.
Third parties are engaged only after due diligence, with written contracts containing anti-bribery clauses and payment against documented services.
All payments are recorded accurately in the books of account.

Date	Employee	Given / Received	Counterparty	Description	Value (₹)	Approved By
[DD/MM/YYYY]	[Employee Name]	[Given/Received]	[Organisation]	[Item]	[Amount]	[Name]
[DD/MM/YYYY]	[Employee Name]	[Given/Received]	[Organisation]	[Item]	[Amount]	[Name]
[DD/MM/YYYY]	[Employee Name]	[Given/Received]	[Organisation]	[Item]	[Amount]	[Name]

5. Procedure

Seek advice from the Compliance Officer at [Email] when unsure.
Report any bribe request or suspected corruption immediately through the Whistleblower channel.
The Compliance Officer reviews the gift register every [Number] months.
Employees in high-risk roles complete annual anti-bribery training and certification.

6. Responsibilities

Leadership: visible commitment and adequate procedures.
Compliance Officer: guidance, register, due diligence oversight.
Finance: accurate records and payment controls.
Employees and third parties: comply and report.

7. Non-compliance

Breach of this policy is serious misconduct and may result in termination and reporting to law enforcement. Third-party contracts may be terminated. No employee will suffer for refusing to pay a bribe, even if the company loses business as a result.

8. Review & Approval

The Compliance Officer will review this policy and risk assessment annually.

Approved by
[Authorised Signatory]
[Designation]
Date: [Date]

Acknowledged by
[Employee Name]
Date: [Date]

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What this template includes

Zero tolerance for bribery, including facilitation payments
Public official rules — no gifts or hospitality without approval
Gifts and hospitality limits — ₹[Amount], with a register
Third-party due diligence and contract clauses
Charitable donations and sponsorship approvals
Accurate records and reporting channels

When to use it

Your teams deal with government departments for licences and approvals
Distributors or liaison agents act for you
Festive season gifting to clients and officials needs rules
Foreign partners or clients require an ABAC policy

How to customise this template

1Set gift and hospitality limits
2Name the compliance officer approving exceptions
3Attach the gift register format
4Add a due diligence checklist for agents
5Include any foreign anti-bribery laws your partners require

HR tips

Facilitation or 'speed' payments are bribes — say so plainly
Prefer branded, low-value festive gifts to cash or vouchers
Record every gift given or received above the limit, including refused ones
Pay agents only against invoices for services actually rendered

Bribery is an offence under the Prevention of Corruption Act, 1988, which also covers commercial organisations, and other laws may apply. Review this policy with a legal adviser, including any foreign laws relevant to your business.

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Frequently asked questions

Is a facilitation payment legal in India?+

No. Payments to public servants to speed up or secure routine work are treated as bribes under Indian anti-corruption law. A good policy prohibits them completely.

Can employees accept Diwali gifts from vendors?+

Small, customary gifts of low value may be accepted if allowed by the policy and recorded in the gift register. Cash, gift cards and expensive items should be declined.

Is the company responsible for bribes paid by agents?+

A company can be held responsible for bribes paid by persons acting on its behalf, unless it can show adequate procedures to prevent such conduct. Due diligence and contract clauses are therefore important.

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