UK Bribery Act 2010
Evidence request list. 20 controls, 20 carrying auditor artefact guidance. Generated from the compliance knowledge graph on 12 September 2026. Published by The Art of Service.
Bribery Act Sections 1 to 6: Offences
It is an offence to offer, promise, or give a financial or other advantage to induce improper performance.
- Documented procedure addressing offence of bribing another person
- Evidence of executive or risk owner approval
- Operational records demonstrating execution
- Independent assurance or review report
- Procedure exists but execution inconsistent
- Owner accountability not codified
- Review cadence missed or undocumented
- Coverage gaps for in scope entities or systems
Defines the relevant functions including public functions, business activities, and employment duties.
- Documented procedure addressing function or activity to which bribe relates
- Evidence of executive or risk owner approval
- Operational records demonstrating execution
- Independent assurance or review report
- Procedure exists but execution inconsistent
- Owner accountability not codified
- Review cadence missed or undocumented
- Coverage gaps for in scope entities or systems
Performance is improper if it breaches a relevant expectation of good faith, impartiality, or trust.
- Anti bribery and corruption policy
- Gifts and hospitality register
- Third party due diligence records
- Training completion records for high risk roles
- Register thresholds not enforced
- Intermediary due diligence shallow
- No targeted training for sales or procurement
- Whistleblowing channel underused
The offence requires intent to influence the official to obtain or retain business or a business advantage.
- Documented procedure addressing influence and business advantage
- Evidence of executive or risk owner approval
- Operational records demonstrating execution
- Independent assurance or review report
- Procedure exists but execution inconsistent
- Owner accountability not codified
- Review cadence missed or undocumented
- Coverage gaps for in scope entities or systems
Includes any person holding legislative, administrative, or judicial positions or performing public functions.
- Anti bribery and corruption policy
- Gifts and hospitality register
- Third party due diligence records
- Training completion records for high risk roles
- Register thresholds not enforced
- Intermediary due diligence shallow
- No targeted training for sales or procurement
- Whistleblowing channel underused
Bribery Act Sections 10 to 15: Prosecution, Penalties and Jurisdiction
No prosecution may be instituted without the consent of the DPP or Director of the SFO.
- Consent capture mechanism design records
- Consent log with timestamp and purpose linkage
- Withdrawal workflow evidence
- Privacy notice version aligned to consent text
- Bundled consent across distinct purposes
- Withdrawal not as easy as granting consent
- Records lack granularity per processing purpose
- Children consent thresholds not enforced
Individuals face up to 10 years imprisonment on indictment and unlimited fines for bribery offences.
- Legal register tracking enforcement risk
- Counsel opinion on liability exposure
- Self disclosure decision records
- Insurance coverage evidence
- Legal register not refreshed for new enforcement actions
- Director and officer awareness thin
- Self disclosure protocols undefined
- Cooperation credit strategy absent
Organisations convicted of bribery offences or failure to prevent bribery face unlimited fines.
- Legal register tracking enforcement risk
- Counsel opinion on liability exposure
- Self disclosure decision records
- Insurance coverage evidence
- Legal register not refreshed for new enforcement actions
- Director and officer awareness thin
- Self disclosure protocols undefined
- Cooperation credit strategy absent
Offences apply to acts committed in the UK or abroad by persons with a close connection to the UK.
- Legal register tracking enforcement risk
- Counsel opinion on liability exposure
- Self disclosure decision records
- Insurance coverage evidence
- Legal register not refreshed for new enforcement actions
- Director and officer awareness thin
- Self disclosure protocols undefined
- Cooperation credit strategy absent
Conduct necessary for the proper exercise of intelligence service functions is a defence.
- Documented procedure addressing defence for intelligence services
- Evidence of executive or risk owner approval
- Operational records demonstrating execution
- Independent assurance or review report
- Procedure exists but execution inconsistent
- Owner accountability not codified
- Review cadence missed or undocumented
- Coverage gaps for in scope entities or systems
Senior officers of organisations are personally liable if bribery is committed with their consent or connivance.
- Consent capture mechanism design records
- Consent log with timestamp and purpose linkage
- Withdrawal workflow evidence
- Privacy notice version aligned to consent text
- Bundled consent across distinct purposes
- Withdrawal not as easy as granting consent
- Records lack granularity per processing purpose
- Children consent thresholds not enforced
Organisations may enter deferred prosecution agreements as an alternative to trial for bribery offences.
- Legal register tracking enforcement risk
- Counsel opinion on liability exposure
- Self disclosure decision records
- Insurance coverage evidence
- Legal register not refreshed for new enforcement actions
- Director and officer awareness thin
- Self disclosure protocols undefined
- Cooperation credit strategy absent
Bribery Act Sections 7 to 9: Failure to Prevent and Adequate Procedures
Defence is available if the organisation had adequate procedures in place to prevent bribery.
- Operating procedures register
- SOP review cadence evidence
- Approval workflow records
- Deviation log with root cause
- SOPs out of date versus current practice
- Deviations rarely logged
- Approvals retrofitted
- Version control inconsistent
An associated person performs services for the organisation including employees, agents, and subsidiaries.
- Documented procedure addressing definition of associated person
- Evidence of executive or risk owner approval
- Operational records demonstrating execution
- Independent assurance or review report
- Procedure exists but execution inconsistent
- Owner accountability not codified
- Review cadence missed or undocumented
- Coverage gaps for in scope entities or systems
Secretary of State must publish guidance on procedures organisations can put in place to prevent bribery.
- Operating procedures register
- SOP review cadence evidence
- Approval workflow records
- Deviation log with root cause
- SOPs out of date versus current practice
- Deviations rarely logged
- Approvals retrofitted
- Version control inconsistent
Due Diligence
Per Bribery Act 2010 Principle 4: due diligence on third parties + agents + business partners + ongoing monitoring.
- UK Bribery evidence for UKBRIBE-3
- adequate procedures + DD partial
Monitoring
Per Bribery Act 2010 Principle 6: monitoring + review + reporting including whistleblower investigations + SFO cooperation + DPA (Deferred Prosecution Agreement).
- UK Bribery evidence for UKBRIBE-5
- adequate procedures + DD partial
Risk Assessment
Per UK Bribery Act 2010 Section 7: failure to prevent bribery offence. Implement adequate procedures defense. Requirements include (a) Proportionate procedures + (b) Top-level commitment + (c) Risk assessment + (d) Due diligence + (e) Communication + Training + (f) Monitoring + Review.
- UK Bribery evidence for UKBRIBE-1
- adequate procedures + DD partial
Top-Level Commitment
Per Bribery Act 2010 Principle 2: top-level commitment + board oversight + governance + accountability.
- UK Bribery evidence for UKBRIBE-2
- adequate procedures + DD partial
Training
Per Bribery Act 2010 Principle 5: communication + training + awareness including role-based + onboarding + refresher + whistleblowing.
- UK Bribery evidence for UKBRIBE-4
- adequate procedures + DD partial
Assembled from the framework’s own control set, so this list is regenerated rather than written and stays current as the graph does. See the UK Bribery Act 2010 framework page.