Anti-Fraud and Anti-Corruption Policy Template

Fraud and corruption can severely damage an organization’s finances, reputation, and trust—both internally and externally. As companies grow and globalize, it becomes increasingly important to have a clear policy that sets expectations for ethical behavior and outlines procedures for identifying and managing dishonest or unethical activity.

This Anti-Fraud and Anti-Corruption Policy helps organizations communicate zero tolerance for fraudulent, corrupt, or unethical practices. It guides employees on how to act with integrity, comply with relevant laws, and report suspected misconduct without fear of retaliation.

This template is ideal for HR, compliance, legal, and finance teams looking to build a more transparent, risk-aware culture.

What the Anti-Fraud and Anti-Corruption Policy Should Include

An effective anti-fraud and anti-corruption policy should cover the following:

• Purpose and scope of the policy
• Definitions of fraud, bribery, corruption, and related misconduct
• Zero tolerance commitment
• Applicability to employees, vendors, partners, and contractors
• Examples of fraudulent or corrupt behavior
• Legal compliance (e.g., Foreign Corrupt Practices Act, UK Bribery Act)
• Employee responsibilities and obligations
• Reporting channels for suspected violations
• Investigation procedures and confidentiality
• Consequences for violations
• Training and awareness requirements
• Policy review and updates

Purpose of This Policy

The purpose of this policy is to establish a clear and consistent framework for preventing, detecting, and responding to fraud, bribery, and corruption within [Company Name]. This policy outlines expectations for ethical behavior and reinforces the company’s commitment to compliance, integrity, and accountability at all levels.

It is designed to protect the company’s assets, reputation, and people while complying with relevant laws and industry standards.

Sample Anti-Fraud and Anti-Corruption Policy

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Effective Date: [Insert Date]
Last Reviewed: [Insert Date]

1. Policy Statement

[Company Name] maintains a zero-tolerance policy toward all forms of fraud, bribery, and corruption. We are committed to conducting business ethically and in compliance with all applicable laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other anti-corruption regulations where we operate.

All employees, officers, contractors, suppliers, and business partners are expected to act honestly and with integrity in all company dealings and to report any suspected misconduct immediately.

2. Scope

This policy applies to:

• All employees (full-time, part-time, temporary, and contract)
• Board members, executives, and officers
• Third parties acting on behalf of [Company Name], including agents, consultants, vendors, and partners
• Any transactions, projects, or activities involving [Company Name] assets or reputation

It applies globally, in all jurisdictions where [Company Name] operates.

3. Definitions

Fraud is any intentional act or omission designed to deceive or mislead others, resulting in financial or personal gain.

Examples include:

• Falsifying financial statements or records
• Misappropriating company assets or funds
• Submitting fake or inflated expenses
• Payroll fraud
• Forging signatures or documents

Bribery involves offering, giving, receiving, or soliciting something of value to influence a decision or gain an unfair advantage.

Examples include:

• Paying cash to secure a government contract
• Giving expensive gifts or hospitality to win business
• Offering kickbacks or commissions to secure deals

Corruption is the abuse of entrusted power for personal or organizational gain, including bribery, embezzlement, nepotism, and favoritism.

4. Legal Compliance

[Company Name] complies with all anti-bribery and anti-corruption laws and expects all employees and partners to do the same, including:

• Foreign Corrupt Practices Act (FCPA)
• UK Bribery Act 2010
• Organization for Economic Cooperation and Development (OECD) Anti-Bribery Convention
• Local anti-fraud and corruption legislation in countries of operation

Violations of these laws may result in severe penalties for both individuals and the company, including fines, imprisonment, and reputational harm.

5. Employee Responsibilities

All employees are responsible for:

• Reading and understanding this policy
• Avoiding any activity that could lead to a violation of this policy or applicable law
• Reporting suspected or actual fraud, bribery, or corruption immediately
• Cooperating fully with investigations
• Completing required training on anti-fraud and anti-corruption practices

Managers and executives must set an example and foster a culture of compliance and integrity.

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6. Prohibited Conduct

The following conduct is strictly prohibited:

• Offering or accepting bribes, kickbacks, or unofficial payments
• Manipulating financial records to hide improper payments
• Falsifying expense reports or invoices
• Using company funds for personal purposes
• Accepting gifts or hospitality that could influence business decisions
• Engaging in collusion or bid-rigging

Gifts and entertainment may only be accepted or provided if they are:

• Reasonable in value
• Infrequent
• Not tied to a specific business decision
• Approved according to [Company Name]’s Gift and Hospitality Policy

7. Reporting and Whistleblower Protections

Employees are encouraged to report suspected fraud or corruption as soon as possible. Reports can be made via:

• Email: [[email protected]]
• Anonymous reporting hotline: [insert number or platform]
• Directly to HR, Legal, or Compliance teams

All reports will be handled confidentially. Retaliation against anyone who makes a good-faith report is strictly prohibited and will result in disciplinary action.

8. Investigations

Reports of suspected fraud or corruption will be investigated thoroughly and impartially. Investigations may include:

• Reviewing documentation or financial records
• Interviewing employees or third parties
• Consulting with external legal or forensic experts

The company will take appropriate corrective and disciplinary action based on the findings, including legal prosecution if necessary.

9. Disciplinary Consequences

Violations of this policy may result in disciplinary action, up to and including:

• Termination of employment or contract
• Civil or criminal prosecution
• Repayment or recovery of misused funds
• Reporting to regulatory authorities

10. Training and Communication

All employees will receive training on this policy during onboarding and at regular intervals. Targeted training will be provided to employees in finance, procurement, legal, and high-risk roles.

This policy will be communicated regularly through internal channels and is available on the [Company Name] intranet or employee handbook.

11. Policy Review and Updates

This policy will be reviewed annually or as required by changes in law or company structure. Updates will be communicated to all employees.

Frequently Asked Questions

What should I do if I suspect fraud or corruption?
Report it immediately through the appropriate channel, such as the anonymous hotline or directly to HR or compliance. Don’t try to investigate it yourself.

Can I accept a gift from a vendor?
Only if the gift is modest, infrequent, and not tied to a business decision. When in doubt, check the company’s Gift and Hospitality Policy or speak with your manager or HR.

What happens if I report someone and it turns out they didn’t violate the policy?
As long as you made the report in good faith, you will not face consequences — and retaliation against you is prohibited.

Are third-party vendors covered by this policy?
Yes. We expect all third parties acting on our behalf to comply with this policy and applicable laws.

How is this different from a general Code of Conduct?
The Code of Conduct sets broad expectations for behavior, while this policy specifically addresses the prevention and handling of fraud and corruption.

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