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Knowledge Base » Business » Training and Educating Employees about Bribery Risks

Training and Educating Employees about Bribery Risks

Last updated on 26th February 2024

In today’s global business landscape, bribery poses significant risks to individuals and businesses alike. Many people think of bribery as something that politicians engage in or something that only affects big businesses. However, in reality, bribery is a widespread form of corruption that can affect businesses of any size. It is estimated that £100 billion of illicit money is laundered through the UK every year.

The National Crime Agency states that bribery poses a serious risk to national security, economic success and international reputation. The repercussions of engaging in bribery extend far beyond legal consequences. Bribery can impact individual reputations, the integrity of your business and your personal and professional relationships. Prioritising educating employees about bribery risks can protect your business and help to create a culture of transparency and ethical conduct in your company.

Understanding the basics of bribery

Understanding the basics of bribery

Bribery is a form of corruption that is a type of serious criminality. Bribery can take many forms, including offering, giving, receiving or soliciting something of value, usually money, gifts, valuable items, favours, benefits or knowledge, with the intention of influencing the actions of another individual – usually someone in a position of power. The aim of bribery is typically to gain an unfair advantage or favourable treatment, to encourage someone to perform their actions or activities improperly or to reward them for already doing so. Bribery typically occurs in business, government and other areas of influence.

Bribery can take multiple forms, including:

  • Commercial bribery: Offering or accepting bribes in business to gain advantages in business transactions, contracts or negotiations.
  • Bribery of public officials: Offering or accepting bribes to influence the decisions or actions of government officials or public servants.
  • Political bribery: Providing financial contributions, gifts or favours to political figures with the expectation of receiving favourable treatment or policies in return.
  • Systemic corruption: Widespread and systematic bribery within an organisation, institution or government, often involving a network of individuals.

There are two main types of bribery: active bribery and passive bribery. Active bribery occurs when an individual offers, promises or gives a bribe. Passive bribery occurs when an individual requests, receives or accepts a bribe. Both active and passive bribery are illegal in the UK and can have serious consequences for individuals and businesses. 

Some examples of bribery include:

  • Offering money to a security employee to gain access to confidential information.
  • Accepting a bonus from management if you ‘look the other way’.
  • Changing the specifics of a contract in exchange for a monetary gift.
  • Bribing a higher authority to receive a promotion by threatening to release private information.
  • Paying foreign officials or customs staff to smuggle unregistered items across the border.
  • An employee awarding a contract to a specific supplier because the supplier promises to kick back a percentage of the contract amount to that employee.
  • Receiving expensive gifts or special treatment from a supplier.
  • Hiring the friends or family of an individual in exchange for favourable treatment or gifts.

The importance of employee training

The Bribery Act 2010 specifies that your business must be liable for preventing an employee from engaging in acts of bribery on behalf of your business, even if you were not aware that bribery was taking place. 

Employee training plays an important role in bribery awareness and preventing bribery from occurring in your organisation. Bribery is a serious ethical and legal issue that can harm a company’s reputation, lead to legal consequences and undermine trust in the business community. By providing comprehensive and effective training programmes, organisations can empower their employees to recognise, prevent and report instances of bribery and protect themselves and their business from accusations of bribery. 

Employee training can help to prevent bribery in your business in the following ways:

  • Awareness and understanding
    A comprehensive bribery training programme helps employees understand what bribery is (including the different types of bribery), how to avoid advertently and inadvertently becoming involved in acts of bribery and what the potential consequences are of engaging in bribery, for both the individual and the business as a whole.
  • Ensures legal compliance
    Training ensures that employees are aware of and understand relevant anti-bribery laws and regulations, such as The Bribery Act 2010. Knowledge of the legal framework helps employees make informed decisions and avoid engaging in activities that could lead to legal repercussions. By providing your employees with training, your business will be demonstrating compliance with the legal framework and this can help to protect your organisation if an employee engages in bribery without your knowledge.
  • You can create company-wide policies and procedures
    Training provides a platform for your organisation to communicate your commitment to ethical business practices and lays out the consequences for violating anti-bribery policies. Employees should be familiar with the organisation’s specific policies and procedures related to bribery prevention and be aware of their responsibilities.
  • Ensures ethical decision-making
    Employee training can help to encourage ethical decision-making across the organisation. By developing ethical decision-making skills, employees are better prepared to resist bribery attempts and act in the best interests of the organisation. Training programmes often include scenarios and case studies that challenge employees to make ethical decisions, allowing employees to practise making decisions regarding bribery.
  • Helps to mitigate risk
    Training helps employees understand the potential risks associated with bribery and provides them with the tools to mitigate those risks. Employees with the appropriate training and knowledge serve as the first line of defence against bribery risks. They are aware of how to identify and report situations or behaviours that may expose the organisation to bribery.
  • Allows you to implement reporting procedures
    During training, employees will learn about confidential reporting procedures and what kind of things they should be reporting. The training will encourage employees to speak up when they witness questionable practices and will help to create a culture of transparency and accountability, where employees understand their role in anti-bribery. Employee training can emphasise the importance of reporting suspicions of bribery through proper channels and can reassure employees that there will be no consequences for them if they do make a report.
  • Allows your organisation to continuously improve
    Regular training sessions will allow your organisation to adapt to evolving risks and update employees on changes in laws and company policies. Continuous learning ensures that employees remain vigilant and proactive in preventing bribery over time.
Elements of effective anti-bribery training

Elements of effective anti-bribery training

The Bribery Act 2010 offers guidance on the procedures and policies businesses and organisations can implement to prevent bribery. To create effective anti-bribery training, your training programme should include:

  • A statement of the individual’s and organisation’s commitment to anti-bribery.
  • An overview of the legal framework and the potential legal consequences of engaging in acts of bribery.
  • A clear explanation of the organisation’s anti-bribery policies and procedures.
  • A description of the ethical business practices your business will follow.
  • The professional consequences of engaging in bribery and any disciplinaries or other formal steps that will be taken in relation to bribery.
  • A variety of training methods, for example e-learning modules, workshops, videos and simulations.
  • Example scenarios involving bribery, including specific examples that are relevant to your organisation or industry.
  • Potential signs of bribery and how to recognise them.
  • A clear description of the reporting procedures.
  • Assurance that whistleblowers will be protected and that reports can be made confidentially.
  • Cultural considerations or differences that should be considered in relation to bribery, e.g. if your business operates in a country where giving gifts is normal.
  • Information about refresher training and opportunities for continuous learning regarding anti-bribery and corruption.
  • Exceptions to the anti-bribery policy (if relevant).
  • Information about the key roles regarding anti-bribery in your organisation, e.g. who is responsible for implementing and reviewing the policy and training and who is the first point of contact for advice and concerns.
  • Information about the actions the organisation will take to reduce the likelihood of bribery occurring.
  • A guide to how ethical business practices should be carried out.

It is also important to tailor the anti-bribery training and the anti-bribery policy to specific roles within your organisation, as people working in different roles will have different responsibilities regarding anti-bribery. It is important that you recognise that different departments and job functions may face unique bribery risks and that this requires specialised training to address different risks effectively. It is also important to ensure the anti-bribery training is tailored to the specific industry you operate in. For example, bribery training should differ for a political organisation compared to a car rental business.

Recognising bribery red flags

Being able to recognise signs of bribery and being aware of bribery red flags is essential for employees working in any organisation with a risk of bribery. This helps your business safeguard against these risks.

Some potential bribery red flags include:

  • Unusual financial transactions, unusual payment methods and offshore transactions.
  • Unusual or disproportionate contracts or bids.
  • Contracts being awarded without due diligence or contracts awarded to an unexpected party.
  • A lack of transparency in financial or business records.
  • Financial or business records being lost or deleted.
  • Irregularities in digital financial or business transactions.
  • Unusual or suspicious relationships or interactions within the organisation, e.g. a family member of a contract partner being hired in a high position without the relevant qualifications.
  • Unexplained or suspicious favours or gifts that have not been documented.
  • An absence of anti-bribery policies (whether in your organisation or in an organisation you are connected to/working with).
  • Unnecessary purchases.
  • Inconsistent pricing.
  • Unjustified or suspicious favouritism or preferential treatment.
  • Incomplete or unusual expenses, e.g. travel or hospitality expenses (expenses are often used to conceal funds given or received through bribery).
  • Excessive gift-giving or hospitality.
  • Lack of proper documentation.
  • Unusual contracting processes.
Bribery reporting and whistleblowing

Reporting and whistleblowing

Implementing clear reporting channels for whistleblowers and offering whistleblower confidentiality and protection from consequences is an integral part of an anti-bribery policy and your training programme. Creating a positive organisational culture that encourages employees to report concerns or suspicions can help to encourage reporting and the early detection and prevention of bribery.  

Whistleblowers play an important role in combatting bribery. To encourage employees to report any concerns or suspicions, your organisation should clearly communicate the existence of reporting channels and the procedures for reporting concerns, ensure anonymity for any employee making a report, provide appropriate training and regularly review and reinforce your anti-bribery policy. 

Creating clear reporting procedures and whistleblower protection can benefit your organisation in multiple ways, including:

  • Early detection: Having reporting channels can help your organisation identify potential instances of bribery before they occur or escalate. This allows you to take quick action and minimise the consequences.
  • Prevention: Knowing how easy bribery is to report and the details of your anti-bribery policy can act as a deterrent and can prevent bribery from taking place.
  • Empowers your employees: Having easily accessible reporting channels can empower your employees to take an active role in maintaining ethical standards and can make them feel part of a positive work culture built on integrity and transparency.
  • Protection for your employees: Having protection for your whistleblowers ensures them that there will be no negative consequences or retaliation to whistleblowing and they will be protected by the organisation. This helps employees to feel safe and secure during the reporting procedure and will likely encourage more employees to make a report.
  • Legal compliance: It is a legal requirement that organisations in the UK comply with anti-bribery laws and implement anti-bribery policies. It is also a legal requirement that whistleblowers are protected, under the Employment Rights Act 1996.
  • Improves employee job satisfaction: For your employees, knowing that your organisation is working to protect them can help to improve their trust in your organisation and can improve their satisfaction at work. This can contribute to higher employee retention and improved company reputation.
  • Demonstrates your organisational values: Effective reporting procedures can highlight your organisation’s commitment to ethical principles and strong values.

Compliance with legal and regulatory frameworks

The main legal framework for businesses and organisations in the UK to be aware of is The Bribery Act 2010. The Bribery Act makes it an offence for a UK citizen or a person or business located in the UK to make or receive a bribe, whether this be directly or indirectly. The Bribery Act covers business and transactions that take place in the UK or in another country. The Act covers organisations in both the private and public sectors. 

Under the Act, a bribe can occur via an associated person acting on behalf of the organisation. This can be an employee, a volunteer, an agent or any person who is associated with the organisation.

Under The Bribery Act, there are four main offences:

  1. It is an offence to bribe another person, including giving, offering or promising a financial reward or another advantage to encourage an individual to perform a specific function or activity improperly.
  2. It is an offence to be bribed, including accepting, receiving or requesting a financial reward or another advantage as a recompense for performing a specific function or activity improperly.
  3. It is an offence to bribe any foreign public official to influence them to acquire or retain business or to gain a business advantage.
  4. It is a corporate offence to fail to prevent bribery in your organisation.

The Bribery Act defines ‘relevant functions’ as activities connected with a business, trade or profession, activities performed in the course of employment, activities performed by or on behalf of a body of persons and functions of a public nature. Relevant functions do not need to occur in the UK for them to be covered by The Bribery Act, as long as the organisation has a connection to the UK. 

Corporate liability is a key feature of the Act, as it makes an organisation responsible for failing to prevent bribery by someone acting on their behalf. If you are convicted of an offence under The Bribery Act, you can be prosecuted and can face imprisonment, a fine and the forced closure of your business or organisation.

Continuous learning and updates

Continuous learning, in the form of ongoing training, refresher courses and regular updates to the anti-bribery policy, is essential for an effective anti-bribery strategy within an organisation. Continuous learning helps to keep employees informed about evolving bribery risks and changes in policies and legislation. 

Continuous learning has multiple benefits for your employees and organisation as a whole, including:

  • Allows you to adapt to changing risks
    The business environment and common bribery practices are constantly evolving. Regular updates allow organisations to address new and emerging bribery risks promptly. Continuous learning ensures that employees are equipped to navigate evolving challenges in the context of bribery prevention.
  • Keeps employees up to date with legal changes
    With the practice of bribery constantly changing, anti-bribery laws and regulations may undergo updates and amendments. Ongoing training ensures that your employees stay up to date with changes in legal requirements, helping the organisation stay compliant and avoid legal consequences.
  • Reinforces policies and procedures
    Refresher courses help to reinforce anti-bribery policies and procedures. Refreshers also help to reinforce key aspects of the anti-bribery policy, meaning your employees are more likely to retain necessary information, such as the signs of bribery to look out for and how to report suspicions of bribery.
  • Increases employee engagement
    Ongoing training demonstrates your organisation’s investment in your employees’ professional development and your commitment to creating a positive work culture. This can make it more likely that your employees will also feel invested in your organisation and may be more likely to take initiative regarding anti-bribery.

Building a culture of integrity

Anti-bribery training is a key component in building a culture of integrity within your organisation. Building a culture of integrity requires the management team to focus on the core values of the organisation. Anti-bribery training plays an important role in employee behaviour and attitude to the workplace. It can also encourage a commitment to ethical conduct and promote a positive work environment. 

Anti-bribery training is a way of modelling ethical behaviour, conduct and decision-making and allows for accountability and consequences when these values are not followed. Because anti-bribery training requires input and participation from employees, they often feel included in decision-making and more confident in their decisions. Input from employees also places emphasis on personal responsibility, which can make employees feel more accountable for their own actions. 

To set the tone for ethical behaviour, leadership should create an environment where employees feel comfortable offering feedback on their concerns. Management can also involve employees in decision-making processes and attend anti-bribery training themselves, to show their commitment to preventing bribery and the equal role everyone in the company plays in the anti-bribery process. To further build a culture of integrity, management should recognise ethical behaviour and positive attitudes and actions. This can reinforce the importance of integrity within the workplace.

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About the author

Nicole Murphy

Nicole Murphy

Nicole graduated with a First-Class Honours degree in Psychology in 2013. She works as a writer and editor and tries to combine all her passions - writing, education, and psychology. Outside of work, Nicole loves to travel, go to the beach, and drink a lot of coffee! She is currently training to climb Machu Picchu in Peru.



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