Anti-Bribery and Anti-Corruption Policy template
FCPA-compliant policy on giving and receiving anything of value, including in dealings with foreign officials.
- Foreign Corrupt Practices Act 1977 (15 USC §78dd-1 et seq.)
- state commercial bribery statutes
What the policy covers
- ZERO TOLERANCEyour company prohibits bribery and corruption in all forms.
- PROHIBITED CONDUCTEmployees, officers, directors, and third parties acting on behalf of the company must not, directly or indirectly:
- GIFTS AND HOSPITALITYModest gifts and hospitality of reasonable value, given or received openly and in line with local customs, are generally acceptable provided they:
- FACILITATION PAYMENTSSmall "facilitation payments" to expedite routine government action are technically permitted under the FCPA but prohibited by this policy.
- THIRD PARTIESWe conduct risk-based due diligence on agents, distributors, and consultants who interact with government officials on our behalf.
- BOOKS AND RECORDSAll payments are recorded accurately and in reasonable detail.
- REPORTING AND TRAININGSuspected violations should be reported via the Whistleblower Policy.
- CONSEQUENCESViolations may result in termination, civil and criminal penalties for the individual (up to $250k / 5 years imprisonment under FCPA), and significant corporate penalties.
Who needs it
Any employer whose people can get hurt, handle personal data or spend company money. Inspectors, insurers and regulators ask to see these first.
Questions people ask
Is a anti-bribery and anti-corruption policy a legal requirement?
It rests on Foreign Corrupt Practices Act 1977 (15 USC §78dd-1 et seq.) and state commercial bribery statutes. Some policies must be written down once a business reaches a certain size or does certain work; others are simply how a tribunal, an inspector or an auditor expects to see that you have thought about it. A clear, dated, signed policy is the evidence either way. Guidance, not legal advice.
Can I change it to suit how we work?
Yes. Inside Work-Lynx it is a starting point: put your company name in, adjust the arrangements to what you actually do, set the review date and publish it. Staff read and acknowledge it on their phones, and you can see who has not.
Is it up to date?
Last reviewed April 2026. The pack is updated when the law moves, and every policy carries a review date so it does not quietly go stale.
How do I get it?
It is preloaded in Work-Lynx with the other 28 policies for the US. Work-Lynx is $3 plus $1.25 per employee, 14 days free, no card, and what you see on the pricing page is the bill.
Who is it for?
Any employer whose people can get hurt, handle personal data or spend company money. Inspectors, insurers and regulators ask to see these first.
All 29 US policies, $3 a month
This policy and 28 others are already in Work-Lynx, alongside GPS clock-in, schedules, timesheets, PTO and an employment-question advisor. $3 base plus $1.25 per employee a month. 14 days free, no card, no sales call.
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