If your business wins contracts, works with agents overseas or hands out client gifts at Christmas, you could be dealing with bribery risk without even realising it. And whether you’re a five-person consultancy or a national enterprise, the Bribery Act 2010 is something you need to understand.
Most HR and compliance leads know the Act exists. But could you say, with confidence, that your organisation meets its actual requirements – and could prove this if asked? In this article, we take a look at the four offences, what ‘adequate procedures’ really means, and which sectors carry the most risk. It also covers where anti-bribery training for employees fits into the picture.
The four offences under the Bribery Act 2010
The Bribery Act 2010 is one of the toughest anti-corruption laws in the world, and it covers more ground than most people expect. There are four distinct offences – and your business could be exposed to all of them at once.
- Bribing another person. Offering, promising or giving a financial or other advantage to induce someone to act improperly.
- Being bribed. Requesting, agreeing to receive or accepting a bribe in exchange for improper conduct.
- Bribing a foreign public official. A specific offence covering payments made to influence officials outside the UK, even indirectly through agents.
- Failure to prevent bribery. A business can be held responsible if an employee, agent or someone else acting on its behalf pays a bribe to win or keep business. This can happen even if senior management knew nothing about it.
That last offence is the one that catches most businesses off guard. You might not have known about or authorised the bribe, but your organisation could still be liable.
What ‘adequate procedures’ really means
If this happens, a business may have a defence if it can show that it had ‘adequate procedures’ in place to prevent bribery. There’s no one-size-fits-all checklist: what counts as adequate will depend on your organisation and the bribery risks it faces.
The Ministry of Justice guidance sets out six principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication (including training), and monitoring and review. In practice, that means:
- A written policy that staff know exists. Depending on your risks, that could mean introducing it during induction, revisiting it through refresher training and making sure staff know where to find it.
- Risk assessments tied to how your business really operates. Higher-risk activities like tendering, gifting and overseas agents need closer scrutiny.
- Due diligence on third parties. Agents, distributors and suppliers acting on your behalf can create liability if you haven’t checked them properly.
- Appropriate training and communication. Keeping records of training completion and assessment results can also help demonstrate the steps you’ve taken to communicate your anti-bribery procedures.
- Regular review, since risks shift as your business grows, enters new markets or changes suppliers.
A similar approach can be seen in the newer failure to prevent fraud offence, which came into force on 1 September 2025. This only applies to large organisations that meet certain criteria. But the principle is familiar: businesses are increasingly expected to put preventative measures in place, not just respond after wrongdoing occurs.
Sectors where bribery risks can be higher
Some sectors and business activities can create greater exposure than others, but no organisation is entirely immune.
- Construction and infrastructure, where subcontracting and public tendering create multiple points of contact with officials and decision-makers.
- Healthcare and pharmaceuticals, where relationships with procurement bodies and clinicians can blur the line between hospitality and influence.
- Public sector suppliers, given the direct contact with officials awarding contracts and grants.
- Import, export and international trade, where agents and intermediaries operate in jurisdictions with weaker enforcement.
- Financial services, where high-value transactions and relationships with clients and third parties can create bribery and corruption risks.
The UK’s own corruption risk rating has been drifting in the wrong direction. Transparency International’s 2025 Corruption Perceptions Index gave the UK a score of 70 out of 100, its lowest since the Index’s methodology was revamped in 2012. That’s down from 82 in 2017. It’s another reason not to treat bribery and corruption as a risk that only affects businesses operating elsewhere in the world.
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Anti-corruption awareness training as your first line of defence
Policies only work if people understand them. Online anti-corruption awareness training is one of the clearest ways to show a regulator, auditor or client that you’ve taken practical steps to prepare your staff. It shows they understand bribery risks and know how to respond to them.
Good training will do three things well:
- Define the grey areas. Gifts and hospitality can create uncertainty for employees, so staff need to understand where legitimate business practice ends and inappropriate influence begins.
- Explain the consequences. Individuals convicted of bribery offences can face up to 10 years in prison and an unlimited fine, while organisations convicted under the Act can also face unlimited fines, alongside serious reputational damage.
- Create a paper trail. Completion certificates and assessment scores give you evidence that training has taken place, not just an assurance that “everyone knows the policy”.
The point of anti-bribery training isn’t simply to tick a compliance box. It’s to help employees recognise risk early enough to do something about it.
Practical steps to demonstrate compliance today
You don’t need a major overhaul to strengthen your position. Start with what you can put in place this quarter.
- Audit your current policy against the six principles in the Ministry of Justice guidance and flag any gaps.
- Map your high-risk touchpoints, including agents, gifts and hospitality, and tendering processes.
- Roll out anti-bribery training across relevant teams, prioritising employees who work with clients, suppliers, agents or other third parties.
- Set a review date, and reassess procedures whenever your risks change, for example when entering a new market, appointing new agents or changing how you win business.
- Keep records. If you’re ever asked to demonstrate ‘adequate procedures’, your evidence needs to be ready, not reconstructed.
Bribery risk rarely announces itself. It shows up in a supplier relationship, a tender process or a well-meaning gift that goes too far. The businesses best placed to manage that risk are the ones who’ve already trained their people, before they needed to.
This article provides general information about anti-bribery and corruption compliance and is not intended to constitute legal advice. Businesses should seek appropriate legal or compliance advice about how the Bribery Act 2010 applies to their individual circumstances.
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