Templates / Attestation Flow

Anti-bribery and corruption policy template

For employees and anyone acting for the company. It bans bribes and facilitation payments, limits gifts and hospitality with a register above a set amount, follows UK Bribery Act and FCPA style expectations, and is re-attested yearly.

• App: Attestation Flow for Confluence
• Category: Governance
• Edition: Picking the pack works in every edition; the paid settings and the starter text need a paid licence
• Re-acknowledge: every 365 days

Note shown to readers:

By acknowledging, you confirm you will not offer, give, request or accept bribes and will record gifts and hospitality as required.

Template. This template is a starting point, not legal advice. Adapt it to your organisation, your contracts and the law that applies to you, and have it reviewed by a qualified professional before you rely on it.

Our position

[Company] does not tolerate bribery or corruption in any form, anywhere we do business, whether by employees or by anyone acting for us.

What is prohibited

• Offering, promising or giving anything of value to improperly influence a decision.
• Requesting or accepting anything of value in return for improper influence.
• Facilitation payments, however small.
• Using agents or intermediaries to do any of the above.

Gifts and hospitality

• Allowed only when modest, infrequent, transparent and not during a tender or negotiation.
• Anything above [amount] must be recorded in the gifts register and approved by [role].
• Never cash or cash equivalents.

Third parties

Agents, distributors and other intermediaries are checked before we work with them and must accept our anti-bribery terms.

Reporting

Report any request, offer or suspicion to [compliance contact] or [speak up channel]. Nobody will suffer for refusing to pay a bribe, even if we lose business as a result.

Includes 2 quiz questions; the answers are not published here. They are shown only in the app's requirement editor, to the person setting up the requirement, who can change them before saving.

1. A supplier offers you an expensive holiday during a tender. What do you do?
   • Accept it quietly
   • Decline it and report the offer to [compliance contact]
   • Accept it if your manager is also invited
2. Are small facilitation payments to speed up routine official actions allowed?
   • Yes
   • No

Edit a Confluence page, insert the Attestation Flow macro, open the requirement editor and pick the pack under Start from a policy pack. It fills the note and the due date; with a paid licence it also fills the re-acknowledgement window, the minimum reading time and the quiz, and can add the starter text to the page. Required readers are never preset: you choose them.

• Attestation Flow for Confluence documentation
• Confluence policy templates: all 16 templates