What Should Anti-Bribery and Corruption Training Cover?

Hard-to-get Taylor Swift tickets, special access to the hottest event in town, or upgraded hotel suites. Fabulous business perks or problematic bribes? It’s not always easy to tell. One thing for sure? It is illegal to offer, promise, or give a bribe; it’s therefore critical to get straight on clear definitions and practical signals to spot trouble early. That’s why anti-bribery and corruption online training exists: to offer your employees a shared playbook for gray areas, align decisions with global laws, and reduce risk across interactions with customers, vendors, and public officials.

What defines a bribe? 

A bribe counts as receiving money and what’s called a thing of value. If you’re exchanging cash or favors, offering kickbacks, or giving special treatment, these count. Bribes and things of value also can be sending someone car service, making a charitable donation, or providing a company sample for personal use.  

When it comes to bribes, it’s not just the item itself that matters, but its scarcity. If something is hard to obtain like sold-out tickets or a luxury item with a long waitlist attached, this counts. 

Some examples of famous business bribes include: 

• Siemens: Bribed officials via “consultants” to win government contracts; paid ~$1.6bn in fines. 

• KBR/Halliburton: Used agents to route ~$180m to Nigerian officials; former president got seven years, and they paid $579m in penalties. 

• BAE Systems: Made large payments tied to overseas defense deals and admitted false compliance statements; they paid $430m. 

• GSK: Bribed doctors and hospitals in China with cash to push products; they were fined $490m and a senior exec received a suspended sentence. 

• Daimler: Bribed officials to win vehicle contracts and gain 50m+ in illegal profits; they paid $185m in fines. 

Where does training come into play? 

Training should show how bribery scenarios surface in workflows. This way, employees can pause, ask questions, and document decisions. Training helps employees identify issues and know what steps to take.  

Why do third parties create risk? 

Nine in ten bribery violations involve third-party intermediaries. The law often treats their conduct as if your company did it. That means vague invoices, urgent “miscellaneous” charges, or secretive arrangements by third-party intermediaries deserve immediate transparency and detail. Because operations span borders, your exposure follows. Policies and training must show how due diligence and accurate records are much-needed risk controls for third-party intermediaries’ relationships. 

What should anti-bribery and corruption online training include?

Effective anti-bribery and corruption training maps to your risks, roles, and geographies. Core topics include identifying subtle forms of bribery and corruption, spotting issues in the supply chain, making sound ethical decisions, fostering personal accountability, and understanding consequences.  

Strong programs add scenario-based practice: distinguishing gifts from bribes, assessing charitable contributions, evaluating lavish hospitality, identifying government officials, maintaining accurate books and records, and performing third-party due diligence. They also address facilitation payment requests, why facilitation payments may go against policy, and what to do when gray areas emerge. 

Additionally, since companies can be subject to the laws of the countries where they are based and the countries where they do business, effective training guides organizations in regard to the FCPA, the UK Bribery Act, and SAPIN II. Good anti-bribery and corruption training programs cover, for example, business-to-business conduct and interactions with government officials.

What red flags should you watch for? 

Red flags include large, vague expenses that must be paid quickly, perhaps with partners wanting secrecy, or with personal perks that feel disproportionate. For example: 

 – If a representative covers lavish accommodations “out of pocket” 

– If a rushed request becomes a facilitation payment 

– When perks or access become things of value 

– Making decisions under pressure 

Final thoughts 

Clear definitions, realistic scenarios, and simple escalation paths make anti-bribery and corruption training critical for success. With shared communication and language about third-party intermediaries, knowing what defines a thing of value, and understanding how to respond to pressure tactics, employees can avoid becoming springboards for future risk and compliance disasters.