Anti-Bribery Training for Employees: What UK Law Expects

Anti-bribery training for employees teaches staff what counts as a bribe, where the line falls on gifts and hospitality, what to do if someone asks for a payment and how to report a concern. No UK law says “train all staff”, but under section 7 of the Bribery Act 2010 a company or partnership of any size is guilty of an offence if someone performing services for it pays a bribe to win or keep business, unless it can prove it had adequate procedures to prevent bribery. The Ministry of Justice guidance on those procedures makes communication, including training, one of its six principles.

This guide explains what the Act covers, what the guidance expects, who needs which training, what to cover and how often to train.

What does the Bribery Act 2010 cover?

The Act has four main offences:

• Bribing another person: offering, promising or giving a financial or other advantage to induce or reward improper performance (section 1). It makes no difference if the bribe goes through a third party.
• Being bribed: requesting, agreeing to receive or accepting such an advantage (section 2).
• Bribing a foreign public official to obtain or keep business (section 6).
• Failing to prevent bribery (section 7). A commercial organisation is guilty if a person associated with it bribes someone to obtain or keep business, or an advantage in business, for the organisation.

Section 7 applies to any company or partnership formed in the UK, wherever it does business, and to any other company or partnership that carries on business in the UK. There is no size threshold, and a trade or profession counts as a business. Under section 8, an associated person is anyone who performs services for or on behalf of the organisation, such as an employee, agent or subsidiary, judged on all the circumstances. The offence applies wherever in the world the bribe is paid.

Under section 11, an individual can be imprisoned for up to 10 years, and an organisation convicted under section 7 faces a fine with no upper limit. Two newer rules raise the stakes:

• Senior managers. Since 29 June 2026, under section 250 of the Crime and Policing Act 2026, when a senior manager acting within their authority commits an offence, such as paying a bribe, the organisation commits it too.
• Public contracts. A conviction for bribery under section 1, 2 or 6, of the company or a connected person such as a director, is a mandatory exclusion ground under Schedule 6 to the Procurement Act 2023. For suppliers to the public sector, that can hurt more than the fine.

Is anti-bribery training a legal requirement?

The Act does not mention training. The defence to section 7 is that the organisation had adequate procedures to prevent bribery, and it is for the organisation to prove that. The Act required the government to publish guidance on those procedures, and the Ministry of Justice guidance sets out six principles:

1. Proportionate procedures
2. Top-level commitment
3. Risk assessment
4. Due diligence
5. Communication (including training)
6. Monitoring and review

Principle 5 says training should be proportionate to risk, but that some training is likely to be effective in establishing an anti-bribery culture whatever the level of risk. The guidance also says:

• general training could be mandatory for new employees, and for agents on a risk basis, as part of induction
• training should be tailored to the risks of specific posts, including higher-risk functions such as purchasing, contracting, distribution and marketing, and people working in high-risk countries
• people involved in “speak up” procedures need training suited to that role
• it may be appropriate to require high-risk associated persons, such as agents, to be trained
• effective training is continuous, and regularly monitored and evaluated
• e-learning is one of the formats available, but whatever the format, people should come away with a firm understanding of what the policies mean in practice for them.

The guidance also lists “deficiencies in employee training, skills and knowledge” as a common internal risk factor when assessing bribery risk.

Small businesses are covered too, in proportion to their risk. The guidance says some small organisations face significant risks and need more extensive procedures, while a very small business may be able to rely on periodic oral briefings to communicate its policies. Either way, record who was briefed and when.

What the SFO looks for

In November 2025 the Serious Fraud Office (SFO) published guidance on evaluating a corporate compliance programme. The SFO uses it when deciding whether to prosecute, whether to offer a deferred prosecution agreement and whether the adequate procedures defence applies. Three points matter for training:

• Having policies in place does not mean a programme is effective. The SFO says it will look at how policies translate into conduct on the ground.
• Organisations of any size can be expected to have at least some compliance arrangements.
• A deferred prosecution agreement can require changes to the organisation’s policies or to the training of its employees.

A training record helps only if it shows the right people understood your actual policy.

Who needs anti-bribery training?

Who	What they need
All employees	What a bribe is, both giving and receiving. Your rules on gifts and hospitality, and the register. Why facilitation payments are not allowed. How to say no, and how to report a request or a concern.
Higher-risk roles	Scenarios from their own work. Sales, business development, purchasing and procurement, contracting, distribution and marketing are named in the guidance, along with anyone working with high-risk countries.
Managers and people who handle concerns	How to approve gifts and hospitality, spot red flags in expenses and third-party payments, respond to a report and protect the person who raised it.
Senior leaders and the board	Their role in top-level commitment and the risk assessment, and their own exposure under the senior manager rule.
Agents, intermediaries and other associated persons	Your policy, the contract terms that apply to them and how to report concerns. The guidance suggests requiring training for high-risk associated persons.

A training needs analysis helps you match the depth of training to the risk in each role, using your bribery risk assessment as the starting point.

What should anti-bribery training cover?

• What counts as a bribe. Any financial or other advantage, offered, promised or given, directly or through someone else, to induce or reward improper performance. Asking for or accepting a bribe is an offence too.
• Gifts and hospitality. The guidance says the Act is not intended to prohibit reasonable and proportionate hospitality and promotional expenditure, while recognising these can be used as bribes. Teach your limits, approvals, register and warning signs, such as lavish hospitality during a tender or gifts to family members.
• Facilitation payments. Small payments to speed up routine government action are illegal under the Act, which has no exemption for them, unlike US law. The guidance accepts that someone threatened with loss of life, limb or liberty may have no choice but to pay. Staff should know to report any such payment straight away.
• Agents and third parties. Commission arrangements, due diligence, contract terms and red flags such as requests for payment in cash or to a third country.
• Donations and sponsorship. Your rules on charitable and political donations and sponsorship.
• Speaking up. Your confidential routes for raising concerns or asking for advice, and the protection people have. Our guide to whistleblowing training covers the law.
• Consequences. For the organisation, for individuals and for winning contracts.
• A short assessment. It checks understanding and gives you evidence for your records.

Some off-the-shelf courses are written around US law, which treats facilitation payments differently, or explain bribery in general terms. UK staff need training on the Bribery Act and your own policy.

Bribery and fraud: one programme

Large organisations also face the offence of failure to prevent fraud, in force since 1 September 2025, whose Home Office guidance follows the same six principles. Our guide to failure to prevent fraud training explains what it expects. One economic crime module covering both, with branches for higher-risk roles, saves staff time and keeps the message consistent. Firms in the money laundering regulated sector also have a direct legal duty to train staff, explained in our guide to anti-money laundering training.

Online or face to face?

E-learning suits the core content. Everyone gets the same message, it reaches agents and overseas staff as well as employees, and it records completions and test results automatically. Scenario-based modules let people in higher-risk roles practise the decisions they might face, such as a supplier offering tickets during a tender.

Live sessions suit senior leaders and high-risk teams, where discussing real dilemmas is the point. In a very small business, a recorded briefing from the owner may be proportionate.

How often should anti-bribery training be repeated?

Neither the Act nor the guidance sets an interval. The guidance says effective training is continuous and regularly monitored and evaluated. We suggest training at induction, an annual refresher for higher-risk roles, and an update whenever your policy, your risk assessment or your markets change, for example before staff start working with a new high-risk country.

For the other training UK employers must or should provide, see our guide to mandatory training for employees in the UK.

How Capytech helps

FastTrack turns your anti-bribery policy, gifts and hospitality rules and real scenarios from your sector into a custom e-learning module with a knowledge check, built from your documents in days. Updates are turned round in 48 hours, so the training keeps up when your policy changes. We can build one economic crime module covering bribery and fraud, with role-based branches.

The Capytech course library has around 9,000 short courses, including titles on bribery and corruption, gifts and hospitality, conflicts of interest and business ethics. These explain bribery in general terms, so where UK law matters we add a short UK module built from your own policy.

The Capytech LMS assigns the right training to each role and keeps the evidence: who completed what and when, and their test results. Its compliance matrix shows who is valid, due or overdue, and certificates carry renewal dates so refreshers happen on time. Our free mandatory training checker shows where anti-bribery training sits among your other training duties.

Frequently asked questions