{"id":223,"date":"2025-01-14T10:23:33","date_gmt":"2025-01-14T10:23:33","guid":{"rendered":"https:\/\/suppliers.duchyofcornwall.org\/?page_id=223"},"modified":"2026-01-20T10:08:40","modified_gmt":"2026-01-20T10:08:40","slug":"bribery-corruption-help-page","status":"publish","type":"page","link":"https:\/\/suppliers.duchyofcornwall.org\/index.php\/bribery-corruption-help-page\/","title":{"rendered":"Bribery Corruption Help page"},"content":{"rendered":"\n

Help notes: ANTI-BRIBERY AND CORRUPTION<\/strong><\/h4>\n\n\n\n

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Does your organisation have adequate measures in place to prevent bribery and corruption (in line with regulatory requirements)?<\/strong><\/h4>\n\n\n\n

This is about having measures in place to prevent bribery in your organisation. Bribery is giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having done so.  <\/p>\n\n\n

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What is a ‘Yes’ for me?<\/strong><\/p>

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A \u2018Yes\u2019 is defined by having adequate measures in place to prevent bribery.   <\/p>\n\n\n\n

If the risk of bribery at the organisation is low – for example if it is very small and only operates within the UK – adequate measures will be much fewer than if the risk is high. The following summary may help you assess what level of risk is relevant for you. (This is not a legal document. Please also see government guidance). <\/p>\n\n\n\n

See Examples of Adequate Measures below for some simple ideas for small organisations.<\/p>\n\n\n\n

Risk of bribery at organisation<\/strong> <\/td>Higher risk <\/strong> 
(more specific measures needed)<\/strong> <\/td>		Lower risk<\/strong> 
(fewer measures needed)<\/strong> <\/td><\/tr>
Size of organisation <\/td>Larger <\/td>Smaller  <\/td><\/tr>
Where organisation operates <\/td>In overseas countries where bribery is prevalent <\/td>In UK only or countries where bribery is not prevalent <\/td><\/tr>
Sector <\/td>e.g. extractive industry; large scale infrastructure <\/td>Not high risk sectors <\/td><\/tr>
Transaction types <\/td>e.g. charitable\/ political contributions; licences\/ permits; public procurement transactions risk  <\/td>Not these transaction types <\/td><\/tr>
Project types <\/td>Complex or high value projects <\/td>Simpler, lower value projects <\/td><\/tr>
Relationships <\/td>e.g. some foreign public officials; politically exposed persons where relevant <\/td>Not these relationships <\/td><\/tr>
Internal factors <\/td>e.g. deficiencies in knowledge; risk taking rewarded; lack of clarity on stances; lack of clear financial controls; lack of clear anti-bribery message <\/td>None of these <\/td><\/tr><\/tbody><\/table><\/figure>\n\n<\/div><\/div>\n<\/div>\n\n
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Does this question apply to me? Is this a regulatory requirement?<\/strong><\/p>

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The question applies to all organisations on some level. If the risk of bribery at the organisation is low, adequate measures will be much fewer than if the risk is high (e.g. a basic understanding of bribery and shared reminder to employees (if any) about the organisation’s stance).<\/p>\n\n\n\n

The Bribery Act 2010 is a legal instrument and there is a criminal offence of failing to prevent bribery.  You will not commit the offence if you can show that your organisation had \u2018adequate procedures\u2019 in place to prevent bribery.  <\/p>\n\n<\/div><\/div>\n<\/div>\n\n

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Examples of adequate measures<\/strong><\/p>

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1. Organisations with lowest risk of bribery <\/em><\/strong>(likely most organisations with <10 employees unless they operate in higher risk areas as described above).  <\/p>\n\n\n\n

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  • High level manager has read and considered the external and internal risks outlined above, and deemed the risk of bribery to be low.<\/li>\n\n\n\n
  • Management has communicated to other employees (if any) about anti-bribery stance, e.g. via an anti-bribery statement or commitment to carry out business fairly, honestly and openly. Simple verbal reminders may be enough. <\/li>\n\n\n\n
  • The organisation\u2019s stance or commitment is stated on the organisation\u2019s internet site (or similar). <\/li>\n\n\n\n
  • No extensive written documentation or policies necessary. <\/li>\n\n\n\n
  • Periodically consider whether risks to the organisation or regulatory environment have changed. <\/li>\n<\/ul>\n\n\n\n

    2. Organisations with higher risk of bribery <\/em><\/strong>(Organisation has considered the risks outlined above, and considered there to be some potential bribery risk).  <\/p>\n\n\n\n