Speaking up and responding to a bribe

Anti-bribery controls only work if people use them, and the most important control of all is a person who says something.

If you are offered a bribe

Refuse clearly and without ambiguity. A joke, a vague deflection, or a "maybe later" can be taken as encouragement, so say plainly that you cannot accept and that company policy forbids it. Do not negotiate, and do not accept "just this once" hospitality as a softer alternative.

Then report it, promptly, to your manager or your compliance contact, even if you refused and nothing came of it. The attempt itself is information the organisation needs: the same person is probably making the same offer to others. Make a written note of what was said, when, where, and by whom, while it is fresh.

If you are asked to pay a bribe, the same applies: refuse, and report the request. The only exception is genuine duress, where your safety or liberty is at risk. In that situation protect yourself first, then report what happened as soon as you are safe.

Raising concerns about others

You may see something that worries you without being personally involved: a colleague's unusually close relationship with a supplier, an invoice that does not add up, a payment routed somewhere strange. You do not need proof, and it is not your job to investigate. Reasonable suspicion, reported honestly, is enough.

Use the routes your organisation provides: your manager, the compliance function, or the confidential whistleblowing channel if you prefer not to raise it openly. UK law protects workers who report genuine concerns in the public interest from retaliation, and any organisation serious about its adequate procedures treats retaliation against a reporter as gross misconduct.

The most damaging phrase in corruption cases is "everyone suspected, nobody said anything". Do not be part of that sentence.