How to use this template. Replace everything in [square brackets]. Delete what does not apply, but not the core rules in sections 1 to 4: they are what makes the policy worth having. Read the supplement for each country where you operate, and have your own lawyer check the final version. A policy that nobody reads protects nobody, so train your people on it (see the training pack) and keep the records it asks for.

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[Company name]: Anti-Bribery and Anti-Corruption Policy

Approved by	[Name and position of the owner or director]
Date approved	[Date]
Version	[1.0]
Policy owner	[Name and position of the person responsible for compliance]
Next review	[Date, within 12 months]
Applies in	[Countries where the company operates, with the matching country supplements]

1. Our commitment

[Company name] competes on the quality of what we supply, the fairness of our prices and the reliability of our service. We do not win business by paying for it, and we do not buy decisions made with other people's money.

We do not offer, promise, give, ask for, agree to receive or accept a bribe, a kickback, a hidden commission or any other improper advantage, in any form, in any country, directly or through anyone else. This applies to everyone who works for us or on our behalf, and it applies whatever the size of the benefit, whatever local custom may be, and whether or not the other person is wealthy, powerful or well disposed to us.

Where doing the right thing costs us an order, we accept the cost. The directors will support anyone who loses business by following this policy, and will not penalise anyone for refusing to break it.

Signed: ____________________ [Name, position] Date: __________

2. Why this matters in our trade

Yachts are run by people who spend money that belongs to someone else: an owner, a charterer, a charter guest. Those people, whether captains, crew, brokers or managers, are agents. They owe the person whose money it is a duty of loyalty. A supplier who pays an agent in secret, in return for an order, damages that duty and exposes both sides to criminal liability in most countries where yachts are supplied. Honest suppliers who refuse to take part lose business to those who do. We want this practice to end, and we want our own house to be beyond reproach.

3. Who and what this policy covers

It applies to:

• every director, officer and employee, permanent or temporary, in every country;
• every agent, distributor, representative, introducer, consultant, freelancer and sub-contractor acting for us or in our name;
• every transaction in which a customer, or anyone acting for a customer, is deciding where to spend money that is not their own.

It covers benefits of every kind: cash, bank transfers, gift cards, goods, wine and spirits, discounts to individuals, free or subsidised travel, hospitality, entertainment, jobs or work for relatives, donations, sponsorship, favours, or anything of value, given to a person or to anyone connected to them.

4. The core rules

Rule 1: No hidden benefits to decision-makers. We never give, offer or promise a benefit to a person who chooses suppliers, places orders or approves spending on behalf of someone else (a captain, a chief stewardess, a purser, a broker, a yacht manager, an owner's representative, a buyer), unless the person whose money is being spent has been told and has agreed in writing in advance.

Rule 2: No hidden benefits to us. We never ask for or accept a benefit from a supplier, contractor or anyone else in return for choosing them, or for any decision we make for another person.

Rule 3: No secrecy. We never agree to keep an arrangement secret from the person whose money it is, from their employer, or from our own compliance function. A request for confidentiality about a commission or incentive is a warning sign and is to be reported to [the policy owner].

Rule 4: Nothing through other people. We do not do through an intermediary, a friend, a relative or a company anything that this policy forbids us to do ourselves.

Rule 5: Nothing off the books. Every payment and every benefit given or received is recorded accurately, in the right account, with the right description.

Rule 6: Speak up. Anyone who is asked to break these rules, or who suspects they have been broken, must say so (section 14). No one will suffer for doing so in good faith.

5. What is allowed

This policy does not forbid ordinary, open business. The following are acceptable, provided they are recorded:

Allowed	Conditions
A price discount	Shown on the customer's invoice, available to the customer and not paid to an individual.
A volume or loyalty rebate	In a written agreement with the customer, applied to the customer's account.
A commission to a broker or agent	Written into a contract that the person whose money is being spent has seen and agreed, paid to the firm (not an individual) from our own account to its own account, against an invoice, and approved under section 9.
Samples and tastings	Of reasonable quantity, offered to the customer's team as a team, with a product purpose, and logged (section 6).
Modest hospitality	Within the limits in section 6, for a genuine business purpose, never linked to a pending decision.
Training and product education	Where it has a genuine professional purpose and is open to the whole team.

6. Gifts, hospitality and samples

We do not give gifts to people who place orders for others. Where a courtesy is appropriate, the following limits apply. The limits are set by [Company name], and a country supplement may set a lower one.

Item	Rule
Gifts	None to decision-makers or their families. A branded item of trivial value (for example a pen or a calendar) may be handed to a team as a team.
Meals and refreshments	At or around a genuine business meeting or tasting, up to [€75] per person. Not lavish, not repeated, and not while a quote, tender or order is pending with the person.
Event invitations	A trade event open to the industry, with a genuine business purpose, up to [€150] per person including travel, with written approval from [the policy owner].
Travel and accommodation	Not offered to individuals. Where a visit to a producer or site is a genuine part of the business relationship, costs are paid by the person's employer or by arrangement in writing with it, with approval from [the policy owner].
Cash, vouchers, gift cards	Never.
Samples	Reasonable for evaluating a product, offered to the team, never to an individual for personal use.
Anything from a customer or supplier to us	The same limits apply in reverse. Anything above the limits is declined or handed to [the policy owner].

Every offer, accepted or declined, above [€25] is entered in the gifts and incentives register within [five] working days. If you are unsure, do not give or accept it, and ask.

7. When someone asks us for a commission

It will happen. A broker, crew member, agent or manager will ask whether a commission, referral fee, discount to them personally, or other benefit is available. The response is the same every time, using the short script:

1. Decline politely and clearly. "We do not pay commission or any benefit to anyone placing an order. Our policy is written down. What we can offer the customer is a discount on the invoice, which they will see and keep."
2. Record it in the register: date, role and organisation of the person asking, what was asked, and your reply. Names are optional in the register but helpful.
3. Tell [the policy owner] the same day if the request was for money, if it came with a threat to take the business elsewhere, or if it was repeated.
4. Do not retaliate, and do not discuss it with competitors.

We treat repeated requests from the same person or firm as information to be reviewed, not as a reason to give in.

8. Facilitation payments, donations and sponsorship

Facilitation payments. We do not make small payments to speed up routine acts by officials or others. If anyone is ever forced to pay to protect their safety, they must report it at once, and it will be recorded accurately. Never make or accept a payment without asking what it is for, checking that the amount is proportionate to the goods or service, and getting a receipt that states the reason. A payment with no receipt and no reason is a warning sign in itself.

Political and charitable donations. We make none in connection with winning or keeping business. Any donation requires prior written approval from [the policy owner], is made openly, to a recognised body, and is recorded.

Sponsorship and show participation. Sponsoring or exhibiting at an industry event is legitimate. It must never be a route for benefits to individuals who place orders, and it must never be conditional on, or linked to, orders or commissions. Before committing to a sponsorship, ask [the policy owner].

9. Brokers, agents, distributors and other intermediaries

Intermediaries are the single largest source of risk, because they can do on our behalf what we may not do ourselves. We therefore:

• Do not pay anyone for introductions unless a written agreement, approved in advance by [the policy owner], sets out the service, the rate, the person whose money is being spent having been told, and the account into which it is paid.
• Carry out due diligence before appointing or paying any intermediary, using the due diligence questionnaire.
• Use a written agreement containing the anti-bribery clauses.
• Pay only against an invoice, into an account in the name of the contracting company, in the country where the services are performed, and never in cash or to a third party.
• Watch for red flags: requests for payment to an individual or an offshore account; a fee out of proportion to the service; vague services; requests for secrecy; a recommendation by the customer's own decision-maker; unusual urgency.
• Review each intermediary at least annually and end the relationship if it breaks these rules.

10. Conflicts of interest

Anyone who has a personal interest that could affect, or look as if it affects, a business decision (for example a relative who works for a customer, or a financial stake in a supplier) must declare it to [the policy owner] before taking part. Declarations are recorded.

11. Sales incentives and pay

Our sales commission and bonus schemes reward legitimate results and are never calculated from, or funded by, payments to customers' employees or agents. No one is paid in a way that gives them a reason to break this policy, and no one is penalised for losing an order by following it.

12. Books, records and payments

• Every transaction is recorded accurately, in the right period and with a truthful description. We do not keep off-the-books accounts or false documents.
• We do not split invoices, back-date documents, or describe a commission as something else.
• Payments are made by traceable bank transfer. Cash payments above [€500] and any cash payment to or from a customer's employee are forbidden.
• Records of gifts, hospitality, intermediaries, training and reports under this policy are kept for the period in the relevant country supplement, and in any case for at least [seven] years.

13. Training, communication and certification

• Everyone reads this policy when they join, and again every year.
• Sales, purchasing, finance and management staff receive training with real examples (training pack). We test understanding, not only attendance.
• Everyone signs the annual compliance certificate.
• We publish our commitment to customers and suppliers and give them this policy on request.

14. Raising concerns

Anyone may raise a concern, in confidence if they prefer, with [the policy owner] or with [alternative contact, such as a director or an external adviser]. We follow the speak-up procedure: we acknowledge every report, take it seriously, investigate it fairly and protect the person who raised it. We do not tolerate retaliation, and retaliation is itself a serious breach of this policy. Where local law gives additional rights or channels, we respect them (see the country supplements).

15. Breaches

A breach is a serious disciplinary matter, up to dismissal or termination of contract. [For employees: a breach is gross misconduct. For contractors and suppliers bound by this policy through a contract: a breach is a material breach of that contract, allowing the company to end it. Ask your lawyer how this works under your governing law.] Where a law may have been broken, we cooperate with the authorities and, where appropriate, report it. A person who breaks this policy cannot excuse it by saying it was in the company's interest or that they were told to.

16. Responsibility, risk assessment and review

• The directors are responsible for this policy and for providing the resources to apply it.
• The policy owner runs the programme day to day: training, the register, due diligence, reports and reviews.
• A risk assessment (template) is carried out at least once a year, and after any incident or change in the business.
• A self-audit (checklist) is carried out at least once a year, and its results reported to the directors.
• This policy is reviewed at least once a year and updated for changes in law and practice.

Appendix: key terms

• Advantage or benefit: anything of value, financial or otherwise.
• Agent (in the sense of agency law): a person who acts for another, such as a captain spending an owner's money, or a broker acting for a charterer.
• Principal: the person for whom an agent acts, and whose money or interests are at stake.
• Hidden or undisclosed commission: a payment or benefit given to or received by an agent in connection with a transaction, which the principal has not been told about and has not agreed.
• Disclosed commission: a payment which the principal has been told about, in advance, and has agreed to, in writing.
• Intermediary: anyone who acts between us and a customer, including agents, brokers, introducers and distributors.
• Acting improperly: acting illegally, unethically, contrary to an expectation of good faith or impartiality, or in abuse of a position of trust. It covers any business or professional activity, including spending someone else's money.
• Perceived influence: a gift or hospitality offered during negotiations or a tender, or just before a decision, can be wrong even if nobody intended to influence anyone, because of how it looks. Decline it, or declare it and ask the policy owner.
• Facilitation payment: a small unofficial payment to speed up a routine action.

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Short form. If a customer or partner asks for a one-page policy, or you want to bind your own suppliers to it by contract, see the short-form policy and the incorporation clause in the contract clauses.

General information and a starting template, not legal advice. Have your own lawyer review it for your circumstances.