Global Anti-Bribery Guidance

Best practice for companies in the UK and overseas

1. Culture & Tone from the Top

Quick Read

Corporate Culture: “The beliefs and ideas that a company has and the way in which they affect how it does business and how its employees behave.”  

- Cambridge English Dictionary


A corporate culture of ethics and integrity creates the enabling environment in which the anti-bribery programme operates. Without such an environment, the anti-bribery programme will operate in isolation without an ethical compass of corporate values or impetus for action.  The key contributing factors to an enabling environment are tone from the top, ethical leadership and employees who understand how they should act when faced with ethically challenging situations, and are motivated to do so.

Key elements:

  • Culture of ethics and integrity: Employees know what is right and will know how to act when faced with ethical challenges.  The company encourages and supports employees to do the right thing.
  • Alignment: The anti-bribery policy and programme are an expression of the corporate values.
  • Tone from the top: The board and management carry the anti-bribery commitment throughout the company through their support, statements, behaviour and activities.
  • Incentives: Design remuneration and incentives so that they do not inadvertently reward behaviour which undermines the company’s anti-bribery commitment.
  • Speak-Up: Encourage a speak-up culture and provide confidential advice and speak-up lines for employees.
  • Reward: Ensure good behaviour and speaking up is visibly rewarded and bad behaviour is visibly penalised.