Bribery Act Compliance – Policies and Guidance

To help protect your organisation against potential prosecution from breaking laws as set out in the Bribery Act, it is essential that you create a set of policies that all associated persons in your organisation are required to read.

Once your policies are ready to publish, you can use DocRead for SharePoint to ensure that all relevant personnel are contacted and asked to self certify that they have read and understood the content.

You policies statements may include the following :

  • Business Expenses Policy. Details on how to claim expenses and guidance on what is acceptable.
  • Code of Conduct Policy. Details how you require your associated persons to conduct themselves in their day to day jobs.
  • Whisteblowing Policy. Details the procedure for communicating a breach of your anti-bribery policy.
  • Business Gifts Policy. Provides guidance on the acceptance of gifts from other parties to the company. This will include corporate hospitality.
  • Business Ethics and Integrity Policy. Explains how you require your associated persons to deal with 3rd parties ethically.

This list isn't exhaustive, as you may have other needs due to the nature of your business. If you don't already have these documents we highly recommend that you consult with legally trained personnel to ensure that adequate anti-bribery clauses are contained.

In addition to these documents, you may also wish to provide training via custom made videos or quizzes which can easily be created in SharePoint using the 'Media player web part' and 'Survey Web Part'. DocRead can be attached to any type of document that can be placed into a SharePoint document library, which means that not only can it be used for simple office documents but also highly interactive web pages*.

* Depending on the level of customisation required, you may need a developer to assist with this.

Amend Contracts to mandate that associated persons must comply with your policies

It also worthwhile amending the contracts between your organisation and it's associated parties. For an employee, for example, you would amend the contract to ensure that they agree to perform compliance training by dates stipulated.

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