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Jurisdiction(s):
United Kingdom
Related legal acts
Key definition
Bribery definition

What does Bribery mean? Bribery describes the offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage to induce or reward the improper performance of a function or to influence a person in a position of trust. In England & Wales, Scotland and Northern Ireland, bribery is principally governed by the Bribery Act 2010, which consolidated and reformed the law. It creates offences of active and passive bribery (sections 1–2), bribery of a foreign public official (section 6), and the corporate offence of failure to prevent bribery by associated persons (section 7), with a statutory defence of having adequate procedures....

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Agents and Intermediaries: Adequate Procedures under the UK Bribery Act 2010—Due Diligence, Red Flags, Contractual Controls, Monitoring, Training, Employee Screening and Whistleblowing

Practice notes
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This Practice Note addresses Agents and other intermediaries in the sphere of anti-Bribery and Corruption. It outlines what an agent or Intermediary is, how engaging agents and intermediaries could expose a commercial organisation to risk, and the steps you might take to lessen those related risks.

What is an agent or intermediary?

Agents and intermediaries are third parties appointed to provide services for, or on behalf of, your organisation, or to represent your interests. This may include:

  • business consultants
  • sales agents
  • third parties retained in relation to government business or actions
  • introducers
  • facilitators
  • lawyers and other professional advisers
  • other third parties who provide services for or on behalf of an organisation in any capacity

Whether a given third-party arrangement is an agent or intermediary relationship is a factual question in each instance. When deciding which anti-bribery and corruption procedures to apply to a third-party relationship, you may assess the extent to which the third party may act autonomously for your organisation in dealings with other parties. You should take all relevant circumstances into account.

Bribery risks involved in working with agents and intermediaries What is prohibited?

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Web page updated on 21/05/2026

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