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United Kingdom
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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Practical red flags for bribery and corruption: due diligence, intermediaries, payments, processes, contracts, gifts and hospitality, and foreign bribery risks

Practice notes
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You are not required to act like the police, but you must stay vigilant for indicators of bribery and corruption and make the kinds of enquiries a reasonable person with your qualifications, knowledge and experience would undertake. This Practice Note highlights common warning signs that typically warrant further enquiry. It draws on examples from the Wolfsberg Anti‑Bribery and Corruption (ABC) compliance Programme Guidance and the International Foreign Bribery Taskforce (IFBT). These factors are not conclusive evidence; they are simply red flags. Give close attention where multiple indicators appear. Such signals can arise during a range of activities, including intermediary engagement, business acquisition or day‑to‑day operations, as well as gifts and entertainment, charitable contributions, and related areas.

General

  • There has been a shift in the behaviour of employees, intermediaries or business partners, for example:
    • an employee who never takes sick leave or holidays, or who insists on personally managing particular customers/clients
    • an employee whose lavish lifestyle does not align with their salary...
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Web page updated on 21/05/2026

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