Who needs a UK Anti-Bribery and Corruption Policy?

Any UK "relevant commercial organisation" within section 7 of the Bribery Act 2010 — that is, any organisation incorporated in the United Kingdom or carrying on a business or part of a business in the UK. There is no minimum size threshold for Bribery Act s.7 — small UK companies are in scope just as much as FTSE 100 plcs. The Ministry of Justice has expressly said that adequate procedures should be proportionate to the risks and the nature, scale and complexity of the organisation's activities, but a complete absence of any policy is unlikely to satisfy the s.7(2) defence in any case.

How is "adequate procedures" judged?

Adequacy is determined on the balance of probabilities by the British court on a case-by-case basis. The MOJ Six Principles are the starting point but are not exhaustive. The court will look at the organisation's risk assessment, due-diligence records, training records, register entries (gifts, hospitality, Speak-Up), Board-level engagement (minutes of bribery-prevention as a standing agenda item), and the implementation of procedures in practice. A policy on paper that is not followed in practice will not constitute adequate procedures. The SFO has been clear that policies without operational substance — what it has called "paper compliance" — do not assist the s.7(2) defence.

What is the ECCTA 2023 Failure to Prevent Fraud offence and does it apply to my organisation?

The Economic Crime and Corporate Transparency Act 2023 introduced a new corporate offence of failure to prevent fraud, in force from 1 September 2025. The offence applies to "large UK organisations" — those meeting at least 2 of: turnover > £36 million, balance sheet > £18 million, > 250 employees in the relevant financial year (s.201 ECCTA 2023). The Home Office Guidance of 6 November 2024 sets out the reasonable-procedures architecture: top-level commitment, risk assessment, proportionate risk-based procedures, due diligence, communication and training, and monitoring and review. The 2026-ready UK ABC policy should integrate this overlay where the organisation is in scope.

What facilitation payment position should our UK policy take?

Best practice in the United Kingdom is "prohibited — no exceptions". Facilitation payments are payments made to a public official to speed up routine, non-discretionary action (visa stamping, customs clearance, business permit issuance). Even small "grease payments" are unlawful under the Bribery Act 2010 — there is no de minimis carve-out in British law (unlike the US FCPA). A narrow safety-only carve-out is acceptable where the alternative is genuine risk to life, health or safety, but the payment must be reported to the CCO immediately and recorded in the Facilitation-Payment Incident Register. SFO prosecutorial discretion is unlikely to be exercised against a UK organisation that has clearly recorded a single safety-driven payment under an otherwise prohibitive policy.

How often should anti-bribery training be delivered?

There is no statutory frequency in UK law, but the MOJ Guidance and SFO commentary suggest at minimum annual mandatory training for all employees and Associated Persons in scope, with specialised modules for higher-risk roles (business development, procurement, government affairs, export controls in the British defence sector). Many UK large organisations now operate an on-joining + every-two-years cadence with quarterly compliance updates from the CCO. Training should be recorded with completion certificates kept centrally — the Training Completion Register is one of the artefacts examined by the SFO and the courts when assessing adequacy of procedures.

Should I include the Criminal Finances Act 2017 in our UK ABC policy?

Yes — strongly recommended. The CFA 2017 sections 45-46 failure-to-prevent-tax-evasion offences apply to all British organisations regardless of size (unlike ECCTA 2023, which is large-organisation only). The "reasonable prevention procedures" defence follows the same six-principle architecture as the Bribery Act, so integration is efficient. Reasonable steps include: enhanced due diligence on tax-adviser intermediaries; red-flag triggers in payment structures (offshore routing without commercial substance); explicit contractual undertakings from associated persons not to facilitate UK or overseas tax evasion; and training that covers tax-evasion facilitation alongside bribery prevention.

What if our organisation discovers a potential bribery incident?

The UK Board should immediately: (a) preserve evidence — implement a legal-hold notice across affected systems, including device images and email archives; (b) appoint an independent investigation team — internal Audit, the CCO, or external legal counsel; (c) consider whether the matter requires reporting to OFSI (sanctions exposure) or to the National Crime Agency (Suspicious Activity Report under the Proceeds of Crime Act 2002); and (d) consider promptly whether self-reporting to the Serious Fraud Office is appropriate, with a view to a possible Deferred Prosecution Agreement under Schedule 17 to the Crime and Courts Act 2013. Self-reporting and proactive co-operation can substantially mitigate British financial penalties and avoid the debarment consequences of corporate conviction.

BusinessUnited Kingdom

UK Anti-Bribery and Corruption Policy Template

Draft a UK Board-adopted Anti-Bribery and Corruption (ABC) Policy structured around the MOJ Six Principles and the Bribery Act 2010 section 7(2) "adequate procedures" defence. Updated for the Economic Crime and Corporate Transparency Act 2023 Failure to Prevent Fraud offence (in force 1 September 2025), the Criminal Finances Act 2017 failure-to-prevent-tax-evasion offences, sanctions compliance under SAMLA 2018, and the SFO Deferred Prosecution Agreement framework. Every British enterprise procurement tender now requires an ABC policy — and a 2011 template no longer suffices. This is the 2026-ready architecture.

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Anti-Bribery and Corruption Policy

Hartfield Engineering Group Plc · Version 4.2 · Effective 2026-06-01 · Next Review 2027-06-01

Bribery Act 2010 s.7(2) — adequate procedures

MOJ Six Principles framework · ECCTA 2023 in scope

This Policy is adopted by the Board of Hartfield Engineering Group plc (Company No. 04829317) of 120 Victoria Embankment, London EC4Y 0DR, a UK public limited company in the precision engineering and defence sector and qualifies as a "large organisation" within the meaning of section 201 of the Economic Crime and Corporate Transparency Act 2023 (and is accordingly within scope of the Failure to Prevent Fraud offence in force from 1 September 2025). Its operations extend internationally and the policy applies extra-territorially in accordance with section 14 of the Bribery Act 2010. The Policy gives effect to the Organisation's obligations under the Bribery Act 2010 and operates as part of the Organisation's section 7(2) adequate procedures defence to the strict-liability corporate offence in section 7 of that Act. It applies to all directors, officers, employees (including temporary and agency workers), agents, distributors, joint-venture partners, subcontractors, consultants, intermediaries, advisers and any other person performing services for or on behalf of any Group company (each an "Associated Person" within the meaning of section 8 of the Bribery Act 2010).

TOP-LEVEL COMMITMENT (MOJ PRINCIPLE 2)

1.1 Statement from the Board. The Board of Hartfield Engineering Group plc commits unequivocally to a culture of integrity. Bribery, corruption and fraud — in any form, in any jurisdiction in which the Group operates — are unacceptable. The Board will provide the resources, oversight and tone required to embed this Policy across the Group and its associated persons, and treats compliance as a defining feature of the Group's licence to operate. The Board confirms a position of zero tolerance to bribery and corruption.
1.2 The Board treats compliance with this Policy and the Bribery Act 2010 as a standing Board agenda item at every Board meeting. 1.3 The Board appoints the Group Chief Compliance Officer and MLRO (Robert James Pemberton) as the senior officer accountable for the design, operation and review of the procedures in this Policy.

PROHIBITION — THE SIX CONDUCT RULES

2.1 No Associated Person shall:
• offer, promise or give any financial or other advantage with the intention of inducing or rewarding the improper performance of a relevant function or activity (section 1 of the Bribery Act 2010);
• request, agree to receive or accept any such advantage (section 2 of the Bribery Act 2010);
• bribe a foreign public official with intent to obtain or retain business or an advantage in the conduct of business (section 6 of the Bribery Act 2010);
• make a facilitation payment, save where expressly permitted under clause 5 below;
• solicit or accept gifts or hospitality outside the limits at clause 5; or
• retaliate, victimise or detrimentally treat any person for raising a concern in good faith under this Policy or under Part IVA of the Employment Rights Act 1996.
2.2 A breach of clause 2.1 is treated as gross misconduct warranting summary dismissal of employees and termination of engagement of other Associated Persons, in addition to civil and criminal liability.

REPORTING AND SPEAK-UP

3.1 Any Associated Person who suspects bribery or corruption (whether by the Organisation, an Associated Person or a counter-party) shall report the concern without delay to the Group Chief Compliance Officer and MLRO at compliance@hartfield-group.com or on +44 (0) 20 7946 0900. An independent external Speak-Up channel is also available: Independent Speak-Up hotline: Safecall UK Ltd, +44 (0) 191 516 7720 (24/7, 50+ languages)
Independent web portal: hartfield.safecall.com
Group CCO direct: cco@hartfield-group.com.
3.2 Reports may be made anonymously and will be treated in the strictest confidence so far as the law permits. Concerns will be investigated promptly, proportionately and fairly. 3.3 Where the disclosure satisfies the qualifying-disclosure criteria in section 43B of the Employment Rights Act 1996, the discloser is protected against detriment under section 47B and from dismissal under section 103A. The Organisation will not tolerate any retaliation against any person who has made a protected disclosure in good faith.

RISK ASSESSMENT (MOJ PRINCIPLE 3)

4.1 The Organisation maintains a documented bribery-and-corruption risk assessment, refreshed annually and on any material change to operations, ownership, geography or products. The assessment covers internal risks (incentive structures, payment authority limits, intermediary relationships) and external risks (country risk per Transparency International Corruption Perceptions Index; sector risk; transaction risk; business-partnership risk).
4.2 The Organisation has identified the following high-risk areas which receive enhanced controls:
Gifts and hospitality (especially during tender processes); facilitation payments solicited in high-risk jurisdictions (CPI score < 50); political donations and lobbying; charitable donations to entities linked to public officials; sponsorships and event hospitality; joint-venture partner relationships (especially state-owned enterprises); commercial agents in defence-export markets; subcontractor engagements above £100,000.

PROPORTIONATE PROCEDURES — GIFTS, HOSPITALITY, FACILITATION, DONATIONS (MOJ PRINCIPLE 1)

5.1 Gifts and hospitality. Gifts and hospitality may be given or received only where reasonable, proportionate, for a legitimate business purpose, transparent, and within the thresholds: any single gift may not exceed £75; any hospitality value may not exceed £250 per head per occasion (excluding modest refreshments at routine business meetings). All gifts and hospitality given or received above £25 in value are recorded in the Gifts and Hospitality Register.
5.2 Facilitation payments. Facilitation payments are prohibited, save where life, health or safety is at imminent risk; in that limited case the payment must be reported to the Group Chief Compliance Officer and MLRO within 24 hours and recorded.
5.3 Political donations. Political donations are permitted only with prior written Board approval and subject to the disclosure requirements in Part 14 of the Companies Act 2006 (donations to political parties, organisations and independent election candidates).
5.4 Charitable donations and sponsorships. Charitable donations and sponsorships are permitted subject to documented due diligence (registered status with the Charity Commission under the Charities Act 2011; verification that the recipient is not a public official or connected with one; sign-off by the Group Chief Compliance Officer and MLRO).

DUE DILIGENCE — ASSOCIATED PERSONS (MOJ PRINCIPLE 4)

6.1 Tiered due diligence. The Organisation applies a tiered due-diligence framework to all proposed Associated Persons before engagement, and on a periodic refresh thereafter, calibrated to the risk presented:
Tier 1 (low risk) — sanctions screening (UK + EU + OFAC); basic identity check; standard contractual ABC clause; refresh every 24 months.
Tier 2 (medium risk) — beneficial-ownership verification (UBO to 25%); adverse-media search (last 5 years); country-risk overlay; PEP screening; enhanced contractual ABC clause; refresh every 12 months.
Tier 3 (high risk) — full integrity due-diligence report from accredited provider; in-country reference checks; anti-bribery questionnaire (signed); audit and information rights; quarterly refresh and continuous monitoring.
6.2 Red flags. The presence of any of the following red flags triggers escalation to the Group Chief Compliance Officer and MLRO and (subject to outcome) Tier-3 enhanced due diligence or refusal to engage:
Refusal to provide beneficial-ownership information; offshore payment routing without commercial substance; recently incorporated in a high-risk jurisdiction (CPI score < 40); family or business relationship with a public official; insistence on cash payments or unusual payment structures; commission rates materially above market norms (> 10% in defence; > 5% in commercial sales); intermediary "consultancy" arrangements without identifiable deliverables; pressure to bypass normal due-diligence process.
6.3 Contractual safeguards. All contracts with Associated Persons include: (i) an anti-bribery warranty and undertaking; (ii) audit and information-request rights; (iii) a right of immediate termination on breach without compensation; (iv) an indemnity against losses arising from breach; and (v) the right to require the Associated Person to implement equivalent procedures with sub-contractors.

COMMUNICATION, TRAINING AND REGISTERS (MOJ PRINCIPLE 5)

7.1 Training. All employees, directors and Associated Persons in scope receive mandatory anti-bribery training on joining + every two years (with quarterly compliance updates by the Group Chief Compliance Officer and MLRO). Specific training audiences: All employees (mandatory e-learning); directors and senior managers (annual classroom or live virtual); high-risk roles in business development, procurement, government affairs and export controls (annual specialised module); finance and procurement teams (additional 2017 Criminal Finances Act module); Board (annual briefing by Group CCO).. Training is delivered in a form appropriate to the audience and recorded centrally with completion certificates.
7.2 Communication. This Policy is published on the Organisation's intranet and external website, included in onboarding materials, referenced in employment and engagement contracts, and reviewed at annual all-hands compliance briefings.
7.3 Registers maintained. The Group Chief Compliance Officer and MLRO maintains the following registers and reviews them quarterly: Gifts and Hospitality Register; Conflicts of Interest Register; Speak-Up Concerns Register; Sanctions-Screening Register; Due-Diligence and Risk-Rating Register; Training Completion Register; Political and Charitable Donations Register; Facilitation-Payment Incident Register.

ECCTA 2023 — FAILURE TO PREVENT FRAUD

8.1 The Organisation acknowledges and adopts the Failure to Prevent Fraud corporate offence in sections 199-206 of and Schedule 13 to the Economic Crime and Corporate Transparency Act 2023 (in force 1 September 2025 by virtue of the Commencement No. 4 Regulations 2025 (SI 2025/349)). Where the Organisation is a "large organisation" within the meaning of section 201 ECCTA 2023, it operates the reasonable fraud-prevention procedures defence (s.199(4)) in line with the Home Office Guidance (6 November 2024): top-level commitment, risk assessment, proportionate risk-based procedures, due diligence, communication and training, and monitoring and review.
8.2 Specified fraud offences in scope include (without limitation) fraud by false representation (Fraud Act 2006 s.2), fraud by failing to disclose information (s.3), fraud by abuse of position (s.4), false accounting (Theft Act 1968 s.17), false statements by company directors (Theft Act 1968 s.19) and cheating the public revenue (common law).

CRIMINAL FINANCES ACT 2017 — FAILURE TO PREVENT TAX EVASION

9.1 The Organisation acknowledges the corporate offences of failure to prevent the criminal facilitation of UK tax evasion (section 45 of the Criminal Finances Act 2017) and failure to prevent the criminal facilitation of overseas tax evasion (section 46 of that Act). The Organisation operates the "reasonable prevention procedures" defence in s.45(2)(b) and s.46(3)(b) in line with HMRC Guidance, including risk assessment, top-level commitment, due diligence, communication, training, and monitoring and review.
9.2 Reasonable steps include red-flag triggers in payment structures (e.g. offshore routing without commercial substance), enhanced due diligence on tax-adviser intermediaries, and contractual undertakings from associated persons not to facilitate UK or overseas tax evasion by any third party.

10.

SANCTIONS — SAMLA 2018 AND OFSI

10.1 The Organisation complies with UK financial sanctions made under the Sanctions and Anti-Money Laundering Act 2018 and administered by the Office of Financial Sanctions Implementation (OFSI). All Associated Persons are screened against the UK Sanctions List on engagement, on counter-party onboarding and on a periodic basis. Any apparent sanctions match is reported to the Group Chief Compliance Officer and MLRO immediately and, where appropriate, to OFSI as required by the relevant sanctions regulations and the Reporting Obligations under The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations in force from time to time.

11.

CO-OPERATION WITH AUTHORITIES — SFO AND DPA

11.1 In the event that conduct potentially constituting a Bribery Act, ECCTA 2023 fraud, Criminal Finances Act 2017 or sanctions offence is identified, the Board will consider promptly whether self-reporting to the Serious Fraud Office (SFO) under the SFO Corporate Co-operation Guidance (2019) is appropriate and proportionate, with a view to a potential Deferred Prosecution Agreement under Schedule 17 to the Crime and Courts Act 2013. Co-operation includes preservation of evidence (including device images), structured internal investigation, disclosure of relevant facts and willingness to make reparations.

12.

MONITORING AND REVIEW (MOJ PRINCIPLE 6)

The Group Chief Compliance Officer and MLRO reports on the operation of this Policy to the Board at every regular Board meeting and at least quarterly. The Board reviews this Policy formally at least annually, and on any material change in the Organisation, its operations or the legal framework. The next scheduled review date is 2027-06-01. The procedures in this Policy will be amended where review identifies any gap relative to the MOJ Six Principles, the ECCTA 2023 Failure to Prevent Fraud guidance, the Criminal Finances Act 2017 guidance or evolving best practice.

13.

GOVERNING LAW AND JURISDICTION

This Policy is governed by and construed in accordance with the law of England and Wales. The criminal-law obligations referenced in this Policy apply with the extra-territorial reach prescribed by section 12 of the Bribery Act 2010 and the equivalent provisions of the ECCTA 2023 and the Criminal Finances Act 2017.

ADOPTED FOR AND ON BEHALF OF HARTFIELD ENGINEERING GROUP PLC

Margaret Eleanor Whitford

Chair of the Board

Date: ____________________

Available as a print-ready PDF or an editable Microsoft Word (.docx) file.

What Is a UK Anti-Bribery and Corruption Policy?

A UK Anti-Bribery and Corruption (ABC) Policy is the Board-adopted document that puts the Bribery Act 2010 section 7(2) "adequate procedures" statutory defence into operation. The Bribery Act 2010 created a strict-liability corporate offence — a UK relevant commercial organisation is criminally liable for the acts of any "associated person" (employee, agent, subsidiary, joint-venture partner, subcontractor, consultant, intermediary) who bribes another person in connection with the organisation's business, anywhere in the world. The only defence is to prove, on the balance of probabilities, that the British organisation had adequate procedures in place to prevent bribery.

The Ministry of Justice published official guidance in March 2011 setting out the "Six Principles" that should inform adequate procedures: (1) Proportionate procedures; (2) Top-level commitment; (3) Risk assessment; (4) Due diligence; (5) Communication (including training); and (6) Monitoring and review. A 2026-ready policy must engage with each of the six and be tailored to the British organisation's size, sector, geographic footprint and risk profile. Generic template language without proper risk assessment and operational machinery (registers, training records, due-diligence reports) is unlikely to make out the s.7(2) defence at trial.

Since 1 September 2025, large UK organisations are also in scope of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) Failure to Prevent Fraud offence — under sections 199-206 and Schedule 13 of that Act, an organisation is criminally liable where an employee, agent, subsidiary or other associated person commits a specified fraud offence for the organisation's benefit, unless the organisation can show "reasonable fraud prevention procedures". The Home Office Guidance of 6 November 2024 sets out a six-principle architecture analogous to the MOJ Bribery Act guidance. A modern British ABC policy should integrate both regimes plus the Criminal Finances Act 2017 failure-to-prevent-tax-evasion offences in ss.45-46.

What's Covered in This UK Template

Our UK template produces a Board-adopted ABC policy structured around the MOJ Six Principles with optional ECCTA 2023, Criminal Finances Act 2017, sanctions and DPA overlays.

Board Signature + CCO Operational Accountability

Single Board-level signatory (Chair / CEO) with the Chief Compliance Officer (or MLRO) named as operational accountable officer — the top-level commitment evidence that Principle 2 of the MOJ Six requires.

Six Conduct Rules Prohibition

Express prohibition tracking Bribery Act 2010 sections 1, 2, 6, plus facilitation payments, gift/hospitality limits and retaliation against good-faith reporters under ERA 1996 Part IVA. Gross-misconduct consequence.

Speak-Up Channel — Internal / External / Both

Confidential reporting framework with anonymous-reporting affordance; for UK large organisations, an independent external hotline (e.g. Safecall, Crimestoppers Integrity Line) is best practice.

Scope of Associated Persons (s.8 BA 2010)

Defines the scope of "associated persons" under section 8 of the Bribery Act 2010 — directors, employees, agents, subsidiaries, JV partners, subcontractors, consultants, intermediaries and advisers anywhere in the British group.

Risk Assessment Matrix (Principle 3)

Expert mode unlocks the risk-assessment clause — internal risks (incentive structures, payment authority limits) + external risks (country risk per Transparency International CPI, sector risk, transaction risk, partnership risk).

Gifts + Hospitality Thresholds (Default £75 / £250)

Monetised gifts and hospitality thresholds (configurable; defaults £75 per gift, £250 per head per occasion) with mandatory Register entry over £25. Modern British procurement-tender expectation.

Facilitation, Political and Charitable Donations

Explicit positions on facilitation payments (prohibited / safety-only carve-out), political donations (prohibited / Board-approved with Companies Act 2006 Part 14 disclosure) and charitable donations / sponsorships (Charities Act 2011 register check).

Tiered Due Diligence (Principle 4)

Expert mode adds the three-tier DD framework: Tier 1 sanctions + identity → Tier 2 enhanced UBO + adverse media + PEP → Tier 3 full integrity due diligence with in-country reference checks and contractual audit rights.

Red-Flag Taxonomy and Training (Principle 5)

Red-flag triggers (UBO refusal, offshore routing, high-risk jurisdiction, public-official connections, unusual payment structures, above-market commissions) + training cadence (annual / biennial / on joining + refresh) + audience by role + completion register.

ECCTA 2023 Failure to Prevent Fraud Overlay

For UK large organisations (≥2 of: turnover >£36m, balance sheet >£18m, >250 employees), the ECCTA 2023 ss.199-206 + Sch 13 Failure to Prevent Fraud clause — in force 1 September 2025, Home Office Guidance 6 November 2024 reasonable-procedures architecture.

Criminal Finances Act 2017 + Sanctions + DPA

CFA 2017 ss.45-46 failure-to-prevent-tax-evasion (applies to all UK organisations regardless of size); SAMLA 2018 + OFSI sanctions compliance; SFO Corporate Co-operation Guidance 2019 + Crime and Courts Act 2013 Sch 17 Deferred Prosecution Agreement framework.

Monitoring and Review Cycle (Principle 6)

Quarterly CCO reporting to the Board + annual policy review + amendment on material change. Next-review-date built in for the British compliance cycle.

How to Create a UK ABC Policy

Follow these steps to draft a UK ABC policy that maps to the MOJ Six Principles and modern statutory currency.

1
Set Organisation Details + Board Signatory + CCO
Enter the UK organisation name, registered address, Companies House number, business sector, organisation size (this drives ECCTA 2023 scope), geographic footprint (UK only / UK + EU / global), policy version, effective date and next review date. Name the Board-level authorising officer (Chair / CEO) and the Group Chief Compliance Officer or MLRO.
2
Draft the Top-Level Board Statement and Speak-Up Channel
The British Board statement is the cornerstone of Principle 2 (top-level commitment) — write it in the Board's own voice rather than copying template language. Pick the Speak-Up channel architecture: internal only (smaller organisations), independent external hotline only, or both (best practice for large UK organisations). Enter Speak-Up contact details.
3
Define Scope, Reporting and Governing Law
Define the scope of "associated persons" under section 8 of the Bribery Act 2010. Enter the primary reporting email and phone for the British compliance function. Pick the governing law (England & Wales / Scotland / Northern Ireland). These are the Free-tier essentials that make the policy valid.
4
Unlock Expert: Risk + Proportionate Procedures + DD + Training
In Expert mode, list the high-risk areas identified by the British risk assessment. Set the gifts and hospitality thresholds (default £75 / £250). Pick the facilitation-payment position (prohibited / safety-only carve-out). Pick the political and charitable donations positions. Define the tiered due-diligence framework (Tier 1 / Tier 2 / Tier 3), the red-flag taxonomy, the training frequency and audience, and the registers maintained by the UK CCO.
5
Add Statutory Currency Overlays and Adopt
In Expert mode, layer the ECCTA 2023 Failure to Prevent Fraud overlay (if large UK organisation), the Criminal Finances Act 2017 failure-to-prevent-tax-evasion overlay (always recommended in the UK), the SAMLA 2018 + OFSI sanctions overlay (for cross-border activity) and the SFO co-operation / Deferred Prosecution Agreement overlay (signals readiness for self-reporting). Download as PDF for Board adoption and publish to the UK intranet, external website and procurement portal.

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Legal Considerations

A UK ABC policy is the operational basis for a Bribery Act 2010 s.7(2) defence and increasingly an ECCTA 2023 s.199(4) defence. Substance matters more than form.

This template is for informational purposes only and does not constitute legal advice. The adequacy of procedures in any UK Bribery Act / ECCTA / Criminal Finances Act case is a fact-sensitive question for the courts. Large organisations should obtain advice from a specialist anti-bribery solicitor and consider an independent compliance audit before placing reliance on the s.7(2) / s.199(4) / s.45(2) defences.

Reviewed for England & Wales corporate compliance practice (June 2026)

Bribery Act 2010 — The Six Conduct Rules

The UK Bribery Act 2010 has four substantive offences: section 1 (bribing another person), section 2 (being bribed), section 6 (bribery of foreign public officials) and the strict-liability section 7 corporate offence (failure of commercial organisations to prevent bribery). Section 7(2) provides the only defence — the British organisation must show that it had adequate procedures in place to prevent persons associated with it from undertaking the conduct in question. Adequacy is judged on the balance of probabilities and is intensely fact-sensitive. The MOJ Guidance March 2011 sets out the Six Principles framework — proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review. A British organisation that has been through a compliance audit and can produce risk-assessment papers, due-diligence reports, training records and register entries is in a meaningfully better position than one that has only a template document.

ECCTA 2023 — Failure to Prevent Fraud (In Force 1 September 2025)

The Economic Crime and Corporate Transparency Act 2023 introduced a new corporate offence in sections 199-206 and Schedule 13 — failure of large organisations to prevent fraud committed by an associated person for the organisation's benefit. The offence came into force on 1 September 2025 by virtue of SI 2025/349. The "large organisation" test in section 201 requires at least 2 of: turnover greater than £36 million, balance sheet total greater than £18 million, or more than 250 employees in the relevant financial year. The Home Office Guidance of 6 November 2024 sets out a six-principle reasonable-procedures architecture similar to the Bribery Act framework. Smaller UK organisations are NOT in scope of ECCTA 2023 but ARE in scope of the Bribery Act 2010 s.7 — there is no de minimis there.

Criminal Finances Act 2017 — Tax-Evasion Facilitation

Sections 45 and 46 of the Criminal Finances Act 2017 created corporate offences of failure to prevent the criminal facilitation of UK tax evasion (s.45) and overseas tax evasion (s.46). Both apply to all British organisations regardless of size — no de minimis threshold. The "reasonable prevention procedures" defence in s.45(2)(b) and s.46(3)(b) follows the same six-principle architecture: top-level commitment, risk assessment, due diligence, communication and training, monitoring and review, proportionality. HMRC has published detailed guidance on what reasonable procedures look like in the UK context. The penalties are unlimited fines and consequential reputational damage — a CFA 2017 conviction also gives the British Government tax authorities a powerful evidence base for related civil and criminal proceedings.

SFO Co-Operation and Deferred Prosecution Agreements

Where conduct potentially constituting a UK Bribery Act, ECCTA 2023 fraud, Criminal Finances Act 2017 or sanctions offence is identified, the British Board should consider self-reporting to the Serious Fraud Office (SFO) under the SFO Corporate Co-operation Guidance (2019). Self-reporting, combined with proactive co-operation (preservation of evidence, structured internal investigation, witness availability, willingness to make reparations), can support a Deferred Prosecution Agreement (DPA) under Schedule 17 to the Crime and Courts Act 2013. DPAs require court approval and have included substantial financial penalties (Rolls-Royce £497m, Airbus £991m UK component) — but they avoid a corporate conviction with its mandatory debarment consequences in UK and EU procurement.

Frequently Asked Questions

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