Anti-Bribery and Corruption Awareness

Anti-Bribery and Corruption Awareness gives learners a practical introduction to risks in everyday business relationships. It explains how concerns may arise through payments, gifts, hospitality, expenses, favours or third-party arrangements, including situations where an improper request is presented as normal business practice.

Across eight teaching modules, learners explore the Bribery Act framework at awareness level, the offering and receiving of advantages, overseas business and interactions with foreign public officials. The course also addresses facilitation payments, conflicts of interest, agents, intermediaries and due diligence.

Realistic situations help learners consider context, purpose, transparency and approval before acting. Examples encourage them to pause when a request appears unusual, keep accurate records and seek guidance when expectations or responsibilities are unclear.

Prevention and speaking up run throughout the course. Learners examine how policies, approvals and proportionate checks support ethical decisions, and how to report a concern without investigating independently or making unsupported allegations.

This introductory training is suitable for employees, contractors and supervisors, including people involved in purchasing, sales, supplier relationships or overseas activity. It supports induction or refresher learning and includes a separate final assessment. Local anti-bribery policies and reporting procedures remain essential to applying the learning at work.

By completing this course, learners will be able to:

●       Explain bribery and corruption in plain workplace terms.

●       Identify warning signs in an offer, request or business arrangement.

●       Recognise situations involving foreign public officials that need guidance.

●       Assess a hospitality scenario against organisational approval procedures.

●       Identify a potential conflict of interest and the route for declaring it.

●       Recognise a request that may involve a facilitation payment.

●       Describe why third-party relationships require proportionate checks.

●       Explain the importance of transparent approvals and accurate records.

●       Choose an appropriate reporting route without investigating independently.

●       Apply an ethical decision-making approach to a realistic business scenario.

Module 1 - Understanding Bribery, Corruption and the Bribery Act 2010

Module Learning Outcomes

By the end of this Module, learners will be able to:

• Identify the four key offences under the Bribery Act 2010.

• Distinguish between individual criminal liability and corporate strict liability.

• Recognise the basic legal requirement for an adequate-procedures defence.

Module 2 - Offering, Promising, Giving, Requesting and Receiving Bribes

Module Learning Outcomes

By the end of this Module, learners will be able to:

• Distinguish the giver-side Section 1 offence from the receiver-side Section 2 offence at awareness level.

• Recognise that a bribe can involve a financial or other advantage, not only cash.

• Recognise that offers, promises, requests or agreements can create bribery risk even where money has not changed hands.

• Know to refuse private arrangements and escalate suspected bribery through authorised routes.

Module 3 - Foreign Public Officials and Overseas Business Risk

Module Learning Outcomes

By the end of this Module, learners will be able to:

• Identify who may fall within the foreign public official concept at awareness level.

• Explain that Section 6 focuses on influencing a foreign public official to obtain or retain business or a business advantage.

• Recognise that local custom does not by itself provide a defence where the written law does not permit the advantage.

• Apply heightened scrutiny to overseas public-sector interactions.

Module 4 - Gifts, Hospitality, Expenses and Conflicts of Interest

Module Learning Outcomes

By the end of this Module, learners will be able to:

• Distinguish genuine, proportionate business hospitality from an improper inducement.

• Recognise that the Bribery Act does not create one universal monetary threshold for gifts or hospitality.

• Consider purpose, timing, proportionality, transparency and legitimate business rationale when assessing risk.

• Follow organisation-specific declaration and approval controls for gifts, hospitality and conflicts.

Module 5 - Facilitation Payments and Other High-Risk Payments

Module Learning Outcomes

By the end of this Module, learners will be able to:

• Explain that facilitation payments have no general exemption under the Bribery Act 2010.

• Distinguish an unofficial facilitation payment from a genuine published official fee paid transparently to the proper authority.

• Recognise procurement, tendering, logistics and certain contributions as higher-risk payment contexts.

• Know to refuse and escalate requests for unofficial payments in line with authorised procedures.

Module 6 - Third Parties, Agents, Intermediaries and Due Diligence

Module Learning Outcomes

By the end of this Module, learners will be able to:

• Explain how associated persons and third parties can create Section 7 bribery risk for an organisation.

• Recognise third-party red flags such as unusually high commissions or unclear services.

• Understand the role of risk-based due diligence and appropriate record-keeping before engagement.

• Recognise that Section 7 is not a blanket rule making an organisation liable for every unrelated third-party act.

Module 7 - Organisational Prevention, Adequate Procedures and Speaking Up

Module Learning Outcomes

By the end of this Module, learners will be able to:

• Identify the six Ministry of Justice principles that support bribery prevention.

• Explain the Section 7 failure-to-prevent offence and the role of the adequate-procedures defence at awareness level.

• Use authorised internal reporting, ethics, compliance or Speak Up routes when concerns arise.

• Provide factual information and avoid conducting an unauthorised investigation.

Module 8 - Recognising Red Flags and Building an Anti-Bribery Culture

Module Learning Outcomes

By the end of this Module, learners will be able to:

• Recognise common bribery red flags such as cash requests, opaque invoices, offshore payments and disproportionate success fees.

• Explain why a strong Speak Up culture supports bribery prevention.

• Treat red flags as indicators requiring review rather than proof of bribery.

• Respond to concerns by recording facts accurately and escalating through authorised routes.