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Anti-Bribery vs Anti-Corruption: What Is the Difference, and Does Your Policy Need Both?
Anti-bribery vs anti-corruption is a question of scope. Bribery is one specific act: offering, giving, asking for or taking something of value to make someone behave improperly. Corruption is the wider family it belongs to, the abuse of entrusted power for private gain, and it takes in fraud, embezzlement, conflicts of interest, trading in influence and money laundering as well. In the UK that distinction has legal weight, because bribery has its own statute with a corporate offence, while most of the rest of corruption is spread across other laws. That is why most companies now write one combined anti-bribery and corruption (ABC) policy rather than two.
The difference in one table
| Anti-bribery | Anti-corruption | |
|---|---|---|
| What it targets | Offering, promising, giving, requesting or accepting an advantage to induce or reward improper performance | Any abuse of entrusted power for private gain, of which bribery is one form |
| Main UK law | Bribery Act 2010 | No single statute: Bribery Act, Fraud Act 2006, Proceeds of Crime Act 2002, Money Laundering Regulations 2017, the common law offence of misconduct in public office, and the failure to prevent fraud offence |
| Corporate offence | Section 7: failure to prevent bribery by an associated person | Section 199 of the Economic Crime and Corporate Transparency Act 2023: failure to prevent fraud, for large organisations, in force since 1 September 2025 |
| Defence for a company | Adequate procedures to prevent bribery | Reasonable procedures to prevent fraud (for the fraud offence) |
| Typical controls | Gifts and hospitality register, third-party due diligence, ban on facilitation payments, contract clauses | All of those, plus conflicts of interest declarations, segregation of duties, expense and payment controls, whistleblowing, anti-money laundering checks |
| Standard | ISO 37001 (anti-bribery management systems) | ISO 37001 plus ISO 37301 (compliance management) and sector rules |
What counts as bribery under UK law
The Bribery Act 2010 creates four offences. Section 1 is bribing another person; section 2 is being bribed; section 6 is bribing a foreign public official; section 7 is the corporate offence of failing to prevent bribery by anyone performing services on the organisation's behalf, including employees, agents, distributors and joint venture partners. An individual convicted under sections 1, 2 or 6 faces up to ten years in prison and an unlimited fine. A company convicted under section 7 faces an unlimited fine.
Three features make the UK Act stricter than most. It covers private-sector bribery as well as bribery of officials. It does not exempt facilitation payments, the small "grease" payments to speed up routine official actions, which the US Foreign Corrupt Practices Act still allows. And section 7 reaches any company that carries on business in the UK, wherever the bribe was paid. Our UK Bribery Act compliance guide goes through each offence and the adequate procedures defence in detail.
What corruption covers that bribery does not
Transparency International defines corruption as "the abuse of entrusted power for private gain". Much of it involves no bribe at all:
- Embezzlement and misappropriation: an employee or official diverting funds they control.
- Conflicts of interest and self-dealing: a buyer awarding a contract to a company owned by a relative, with no payment changing hands.
- Nepotism and cronyism: hiring or promoting on connections rather than merit, particularly in the public sector.
- Trading in influence: selling access to decision-makers, which is an offence in some countries even where no official is paid.
- Fraud: false accounting, false invoicing and bid rigging.
- Money laundering: disguising the proceeds of any of the above.
These are policed under separate UK laws, and since 1 September 2025 a large organisation can be prosecuted for failing to prevent fraud committed by an employee or agent for its benefit. That offence mirrors the section 7 model and is the main reason anti-corruption programmes have grown beyond bribery. See our guide to the failure to prevent fraud offence.
Why the distinction still matters in practice
It changes how you assess risk
A bribery risk assessment looks outward: which markets, sectors, intermediaries and government touchpoints create pressure to pay. A corruption risk assessment also looks inward: who can approve their own payments, who controls supplier onboarding, where conflicts of interest are undeclared. A company can score low on bribery risk (no overseas agents, no public contracts) and still carry real corruption risk from weak internal controls.
It changes who owns the controls
Bribery controls usually sit with compliance and legal. Corruption controls reach into finance (payment approval, segregation of duties), procurement (supplier vetting, tender rules) and HR (recruitment, conflict declarations). A policy that only speaks to the compliance team misses most of them.
It changes the defence you can run
Under section 7, the only defence is that the company had adequate procedures to prevent bribery. The Ministry of Justice guidance sets out six principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review. Under the failure to prevent fraud offence, the defence is reasonable procedures, assessed against the Home Office's guidance built on the same six themes. A combined ABC programme that documents both is the cheapest way to be able to run either defence.
One policy or two?
For almost every organisation, one. A combined anti-bribery and corruption policy avoids duplicated rules on gifts and hospitality, gives staff a single place to look, and lets one risk assessment feed both sets of controls. Keep the bribery rules precise, because that is where the strict statute bites, and set out the wider corruption rules alongside them. A workable structure:
- Scope and who it applies to, including agents and other associated persons.
- Definitions of bribery, facilitation payments and corruption, with examples.
- Gifts, hospitality and expenses, with financial thresholds and a register.
- Conflicts of interest, with an annual declaration.
- Third-party due diligence and contract clauses.
- Charitable donations, sponsorship and political contributions.
- Record keeping and payment controls.
- Reporting concerns and protection for whistleblowers.
- Training, monitoring, and consequences for breaches.
The policy should sit under your code of conduct rather than replace it. Our guide on how to write a code of conduct shows where it fits.
Frequently Asked Questions
What is the difference between bribery and corruption?
Bribery is a specific act: offering, giving, requesting or accepting an advantage to induce or reward improper conduct. Corruption is the wider category of abusing entrusted power for private gain, which includes bribery but also embezzlement, fraud, conflicts of interest, nepotism and money laundering.
Is all bribery corruption?
Yes. Bribery is one form of corruption. The reverse is not true: an undeclared conflict of interest or an embezzlement is corrupt without any bribe being paid.
Is there a UK Anti-Corruption Act?
No. The UK has the Bribery Act 2010 for bribery, and deals with other forms of corruption through the Fraud Act 2006, the Proceeds of Crime Act 2002, money laundering regulations, the common law offence of misconduct in public office and the failure to prevent fraud offence.
What is an ABC policy?
An anti-bribery and corruption policy: one document covering the Bribery Act offences and wider corruption risks, with rules on gifts and hospitality, facilitation payments, conflicts of interest, third parties, donations and whistleblowing.
Are facilitation payments legal in the UK?
No. The Bribery Act 2010 has no exemption for facilitation payments, unlike the US Foreign Corrupt Practices Act. A payment made under duress to protect someone's safety is treated differently, and should be recorded and reported.
What defence does a company have for failing to prevent bribery?
Only that it had adequate procedures designed to prevent people associated with it from bribing. The Ministry of Justice guidance frames these around six principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.
Sources
- Bribery Act 2010, legislation.gov.uk: sections 1, 2, 6, 7 and penalties.
- Ministry of Justice, Bribery Act 2010 guidance: the six principles of adequate procedures.
- Home Office, guidance on the failure to prevent fraud offence: scope, reasonable procedures and the 1 September 2025 start date.
- Transparency International, What is corruption?: the "abuse of entrusted power for private gain" definition.