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Anti-Bribery and Anti-Corruption (ABAC) Policy Template | Free Download

Integrity is the backbone of a resilient enterprise. As global regulations tighten, organizations must move beyond "good intentions" to documented, enforceable ethics. Our Anti-Bribery and Anti-Corruption Policy template provides the legal framework you need to prevent fraud, manage third-party risks, and build a transparent culture that auditors and stakeholders can trust.

What is this Template For?

This template provides a clear, legal-grade framework that prohibits unethical business conduct. It acts as your organization’s "Code of Conduct" regarding financial integrity. It is designed to ensure that no one—from the CEO to third-party contractors—uses improper influence to gain a business advantage.

It covers critical risk areas:

  • Government Relations: Preventing improper payments to officials.
  • Commercial Transactions: Ensuring sales and procurement are based on merit, not "kickbacks."
  • Conflicts of Interest: Preventing personal gain from compromising company decisions.
  • Third-Party Risks: Holding partners and suppliers to your same high standards.

Why Use This Template? (The Purpose)

The cost of corruption isn't just financial fines; it’s the total loss of stakeholder trust. This template serves three vital purposes:

  1. Legal Safe Harbor: Many regulations (like the UK Bribery Act) offer a defense if an organization can prove it had "adequate procedures" in place to prevent bribery. This template is the foundation of those procedures.
  2. Risk Identification: It forces the organization to look at "Red Flags"—such as excessive gifts or unusual payment structures—before they turn into a crisis.
  3. Cultural Alignment: It aligns with ISO/IEC 27001:2022 by fostering a "culture of integrity." Security isn't just about firewalls; it’s about ensuring the people behind the keyboards are acting ethically.

How to Use the ABAC Policy Template

To get the most out of this download, treat it as a living document rather than a "set and forget" file. Follow these steps:

Step 1: Define Your Reporting Channels

A policy is useless if employees are too afraid to speak up. Use Section 7 of the template to specify your confidential reporting mechanisms (e.g., an anonymous hotline or a dedicated compliance email). Ensure your "Non-Retaliation" stance is clearly stated.

Step 2: Set "Thresholds" for Gifts & Entertainment

The template prohibits "excessive" gifts. To make this practical, you must define what "excessive" means in your local currency (e.g., "Any gift over $50 must be recorded in the Gift Register").

Step 3: Integrate with Third-Party Due Diligence

Don't just sign contracts; use the criteria in Section 4 to vet your partners. Ask for their ABAC policies and include "Audit Rights" in your contracts so you can verify their compliance.

Step 4: Launch Role-Based Training

Use the training requirements in Section 6 to educate your team. Sales and Procurement teams should receive more intensive training than departments with lower external exposure.