Anti-Bribery and Corruption
What this lesson covers:
- What is bribery?
- Acceptable and unacceptable practices
- Responsibilities and the legal implications
- How to report concerns and identify red flags
Start Lesson
A quick introduction
Watch this short video about anti-bribery and corruption and the impact it can have. Once the video finishes, click the arrow at the bottom of the screen to continue.
What is Bribery?
Bribery includes offering, giving, or accepting inducements such as money, gifts, hospitality, services, or discounts to gain improper advantage. Click below to explore some examples of bribery.
Receiving personal benefits from suppliers / partners, or failing to declare relationships that influence decisions
Offering jobs or promotions to influence a decision, including hiring someone connected to a decision-maker.
Gifts or hospitality when they are excessive, frequent, or intended to influence a decision.
Offering or accepting money or financial rewards to influence a business decision.
Title
Title
Employment-related
Conflicts of interest
Use this side to give more information about a topic.
Use this side to give more information about a topic.
Title
Title
Cash or financial incentives
Gifts and hospitality
Use this side to give more information about a topic.
Use this side to give more information about a topic.
Subtitle
Subtitle
Subtitle
Subtitle
Next card
Next card
Next card
Is this considered a bribe?
Gifts and Hospitality
Reasonable gifts and hospitality may be offered or accepted where they support legitimate business relationships and are proportionate, transparent, and infrequent. They must never be used to influence, or appear to influence, a business decision.Let's look at the acceptable examples below:
Accepting stationery or notebooks, as part of a meeting or event
Acceptable
Seasonal or goodwill gifts of low value, such as a box of chocolates shared with a team.
Acceptable
Refreshments, such as tea, coffee, or a light lunch provided during a business meeting.
Acceptable
Next card
Next card
Gifts and Hospitality
Now let's explore what would be considered unacceptable and demonstrates a breach of the UK Bribery Act.
Gifts or hospitality offered during a tender, contract renewal, or procurement process.
Unacceptable
Personal discounts, services, or benefits for individual employees rather than Cuckoo.
Unacceptable
Cash, vouchers, gift cards, or prepaid cards of any value.
Unacceptable
Next card
Next card
Spotting the risks
A risk is any situation where a gift, payment, relationship, or request could influence, or appear to influence, a business decision, or where transparency and proper records are missing. Bribery often does not look obvious. It is frequently disguised as routine business activity, informal arrangements, or “how things are usually done”. Look below at some common risk indicators.
Be aware if a request is made to speed things up, bend the rules, or keep something off the record.
Invoices are vague, incomplete, or do not reflect the work carried out.
Someone suggests that a favour is “expected” in return for help or access.
A gift or hospitality is offered just before or during a tender, renewal, or inspection.
Payments are requested in cash, through unusual routes, or to personal accounts.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Title
Let's just keep this between us
Title
Let's not worry about the detail
Title
You scratch my back i'll scratch yours
Title
Here's a little something
Title
There's a technical issue our side
Write a brief description here
Write a brief description here
Write a brief description here
Write a brief description here
Write a brief description here
Next card
Next card
Next card
Next card
The legal implications
Anti-bribery and corruption is not just about acting ethically. It is a legal requirement under the UK Bribery Act 2010, one of the strictest anti-bribery laws globally.
Click here to explore the key offences under the UK bribery act
The Act creates three main offences
Where a company does not have adequate controls in place to prevent bribery by employees or third parties.
Offering or giving something of value to influence a decision
Failure of an organisation to prevent bribery
Requesting or accepting a bribe
Title
Title
Title
Bribing another person
Use this side to give more information about a topic.
Use this side to give more information about a topic.
Use this side to give more information about a topic.
Being bribed
Subtitle
Subtitle
Subtitle
Next card
Next card
This means organisations must actively prevent bribery — not just respond to it.
Who does this apply to?
The Act applies to all employees, contractors and temporary workers and, anyone acting on Cuckoo’s behalf, including suppliers, agents and partners. Cuckoo can be held legally responsible for bribery carried out even if senior leaders were unaware.
Consequences of a breach
If Cuckoo, or individuals are found in breach of the UK Bribery Act 2010, there can be very serious consequences ranging from disciplinary action to 10 years imprisonment. Explore some of the consequences below.
For Cuckoo
For Individuals
- Unlimited fines
- Serious reputational damage and loss of trust
- Contract termination or exclusion from future business
- Increased regulatory scrutiny
- Disciplinary action, including dismissal
- Unlimited fines
- Up to 10 years’ imprisonment in serious cases
- Long-term damage to personal reputation and career
Record keeping and third-party relationships
Accurate and transparent record-keeping is a legal requirement and a key safeguard against bribery. All employees must declare and record all gifts and hospitality, regardless of value, in line with our Cuckoo policy. This ensures transparency and protects both individuals and the organisation.
All gifts and hospitality must be logged using the 'Gifts and Hospitality register' which can be found on The Nest. Just head to 'Support' > 'Gifts and Hospitality Register'.
Raising concerns
If you spot a risk or something doesn’t feel right, you should:
Speak to the People or Legal team
You can also raise concerns with our People Team or our Legal Team.
Pause
If something doesn't feel right, do not proceed.
Speak to your manager
If you're comfortable, inform your manager straight away.
Contact the whistleblowing hotline
Visit the Nest to find details of our Whistleblowing hotline.
Your commitment
At Cuckoo we have a zero-tolerence approach to any form of bribery or corruption. It's important that you understand our policy and ensure that all business dealings are ethical and transparent.
There are two policies you should take the time to read and understand. Our anti-bribery and corruption policy and our Gifts and hospitality policy.
View Policy
View Policy
Thank you
Thank you for completing this module on anti-bribery and corruption. By acting with integrity, speaking up about concerns, and following our policies, you help maintain trust, fairness, and a strong ethical culture across Cuckoo.
Anti-Bribery and Corruption
Brian Ranson
Created on January 8, 2026
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Transcript
Anti-Bribery and Corruption
What this lesson covers:
Start Lesson
A quick introduction
Watch this short video about anti-bribery and corruption and the impact it can have. Once the video finishes, click the arrow at the bottom of the screen to continue.
What is Bribery?
Bribery includes offering, giving, or accepting inducements such as money, gifts, hospitality, services, or discounts to gain improper advantage. Click below to explore some examples of bribery.
Receiving personal benefits from suppliers / partners, or failing to declare relationships that influence decisions
Offering jobs or promotions to influence a decision, including hiring someone connected to a decision-maker.
Gifts or hospitality when they are excessive, frequent, or intended to influence a decision.
Offering or accepting money or financial rewards to influence a business decision.
Title
Title
Employment-related
Conflicts of interest
Use this side to give more information about a topic.
Use this side to give more information about a topic.
Title
Title
Cash or financial incentives
Gifts and hospitality
Use this side to give more information about a topic.
Use this side to give more information about a topic.
Subtitle
Subtitle
Subtitle
Subtitle
Next card
Next card
Next card
Is this considered a bribe?
Gifts and Hospitality
Reasonable gifts and hospitality may be offered or accepted where they support legitimate business relationships and are proportionate, transparent, and infrequent. They must never be used to influence, or appear to influence, a business decision.Let's look at the acceptable examples below:
Accepting stationery or notebooks, as part of a meeting or event
Acceptable
Seasonal or goodwill gifts of low value, such as a box of chocolates shared with a team.
Acceptable
Refreshments, such as tea, coffee, or a light lunch provided during a business meeting.
Acceptable
Next card
Next card
Gifts and Hospitality
Now let's explore what would be considered unacceptable and demonstrates a breach of the UK Bribery Act.
Gifts or hospitality offered during a tender, contract renewal, or procurement process.
Unacceptable
Personal discounts, services, or benefits for individual employees rather than Cuckoo.
Unacceptable
Cash, vouchers, gift cards, or prepaid cards of any value.
Unacceptable
Next card
Next card
Spotting the risks
A risk is any situation where a gift, payment, relationship, or request could influence, or appear to influence, a business decision, or where transparency and proper records are missing. Bribery often does not look obvious. It is frequently disguised as routine business activity, informal arrangements, or “how things are usually done”. Look below at some common risk indicators.
Be aware if a request is made to speed things up, bend the rules, or keep something off the record.
Invoices are vague, incomplete, or do not reflect the work carried out.
Someone suggests that a favour is “expected” in return for help or access.
A gift or hospitality is offered just before or during a tender, renewal, or inspection.
Payments are requested in cash, through unusual routes, or to personal accounts.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Use this side of the card to provide more information about a topic. Focus on one concept. Make learning and communication more efficient.
Title
Let's just keep this between us
Title
Let's not worry about the detail
Title
You scratch my back i'll scratch yours
Title
Here's a little something
Title
There's a technical issue our side
Write a brief description here
Write a brief description here
Write a brief description here
Write a brief description here
Write a brief description here
Next card
Next card
Next card
Next card
The legal implications
Anti-bribery and corruption is not just about acting ethically. It is a legal requirement under the UK Bribery Act 2010, one of the strictest anti-bribery laws globally.
Click here to explore the key offences under the UK bribery act
The Act creates three main offences
Where a company does not have adequate controls in place to prevent bribery by employees or third parties.
Offering or giving something of value to influence a decision
Failure of an organisation to prevent bribery
Requesting or accepting a bribe
Title
Title
Title
Bribing another person
Use this side to give more information about a topic.
Use this side to give more information about a topic.
Use this side to give more information about a topic.
Being bribed
Subtitle
Subtitle
Subtitle
Next card
Next card
This means organisations must actively prevent bribery — not just respond to it.
Who does this apply to?
The Act applies to all employees, contractors and temporary workers and, anyone acting on Cuckoo’s behalf, including suppliers, agents and partners. Cuckoo can be held legally responsible for bribery carried out even if senior leaders were unaware.
Consequences of a breach
If Cuckoo, or individuals are found in breach of the UK Bribery Act 2010, there can be very serious consequences ranging from disciplinary action to 10 years imprisonment. Explore some of the consequences below.
For Cuckoo
For Individuals
Record keeping and third-party relationships
Accurate and transparent record-keeping is a legal requirement and a key safeguard against bribery. All employees must declare and record all gifts and hospitality, regardless of value, in line with our Cuckoo policy. This ensures transparency and protects both individuals and the organisation.
All gifts and hospitality must be logged using the 'Gifts and Hospitality register' which can be found on The Nest. Just head to 'Support' > 'Gifts and Hospitality Register'.
Raising concerns
If you spot a risk or something doesn’t feel right, you should:
Speak to the People or Legal team
You can also raise concerns with our People Team or our Legal Team.
Pause
If something doesn't feel right, do not proceed.
Speak to your manager
If you're comfortable, inform your manager straight away.
Contact the whistleblowing hotline
Visit the Nest to find details of our Whistleblowing hotline.
Your commitment
At Cuckoo we have a zero-tolerence approach to any form of bribery or corruption. It's important that you understand our policy and ensure that all business dealings are ethical and transparent.
There are two policies you should take the time to read and understand. Our anti-bribery and corruption policy and our Gifts and hospitality policy.
View Policy
View Policy
Thank you
Thank you for completing this module on anti-bribery and corruption. By acting with integrity, speaking up about concerns, and following our policies, you help maintain trust, fairness, and a strong ethical culture across Cuckoo.