Anti-bribery training pack: 60-minute session, scenarios and quiz

Training is the part of a policy most likely to be skipped and most likely to be asked about. This pack lets you run a proper session in an hour, with no outside trainer. Run it when people join and every year after. Test understanding, not attendance.

Who: everyone who deals with customers, buys, pays or manages. Time: 60 minutes. Led by: [policy owner] or a director. Bring: the policy, the sales code and the register.

Agenda

Time	Item	Notes
0:00	Why we are here (5 min)	The director says, in their own words, that we would rather lose an order than break the policy, and that no one will be punished for refusing.
0:05	The idea in one sentence (5 min)	Anyone spending someone else's money owes that person loyalty. A secret benefit from the other side breaks that loyalty. Both giving and taking are crimes in most countries.
0:10	The line between commission and kickback (10 min)	Walk through Commission or kickback?: told, agreed, written, paid to the firm, no effect on advice.
0:20	Our rules (10 min)	The six rules in the sales code. What is allowed and what is not.
0:30	Scenarios (20 min)	Split into pairs. Each pair takes three scenarios and says what they would do. Compare with the answers below.
0:50	The quiz (7 min)	On paper, alone. Mark it together.
0:57	Questions, and sign-in (3 min)	Everyone signs the attendance sheet and the annual certificate.

Ten scenarios

1. The chief stewardess asks for a "little something" for the boat. She says other suppliers give 10% on wine. What do you do?

Decline politely, using the script. Offer an invoice discount the owner will see. Record the request. Tell [policy owner] if it is repeated. Do not assume she is a bad person: she is asking because it is normal where she works.

2. A charter broker sends you a client's order and asks you to add 8% and invoice it to him separately.

No. This is a hidden commission, paid out of the client's money, with the invoice used to disguise it. Decline, record, and report to [policy owner] the same day. If it continues, we stop dealing with the broker.

3. A captain suggests you take him to dinner after a large order is confirmed.

A modest meal at a genuine business meeting may be acceptable under the policy, within the limit, never while an order is pending, and logged. A lavish evening after an order "as a thank-you" is not. When in doubt, say no.

4. A customer's management company says it will give you more work if you fund a trip for its team to visit a producer.

No. This is a benefit linked to orders. If a producer visit has genuine business value, it can be arranged with the company's own approval and funding, in writing, with [policy owner]'s sign-off.

5. An agent you do not know offers to introduce you to three brokers for "an introduction fee, paid in cash, no paperwork".

Decline. Cash, no paperwork and an unknown agent are all red flags. Any payment to an intermediary needs due diligence, a written agreement and an invoice.

6. A colleague tells you he has an "arrangement" with a captain and you should not mention it to the owner.

Do not take part, and do not ignore it. Report it to [policy owner] or through the speak-up procedure. Rule 3 is that we do not keep secrets from the person whose money it is.

7. A show organiser says exhibitors who "look after" the brokers will get better stand positions.

Sponsorship and exhibiting are legitimate, but benefits to individuals who place orders are not. Do not agree. Ask [policy owner] before committing to any sponsorship, and record the approach.

8. A fuel supplier or port agent offers you a percentage of every tonne you refer to them.

This is a commission on the client's spend paid to an intermediary. Unless the client knows and has agreed, in writing, it is forbidden. Decline.

9. A competitor tells you everyone pays and you are naive.

They may be right that some do. That is not a defence in any country we operate in, and it is the reason we make our position public. Record the conversation, and do not discuss prices or customers with competitors.

10. A long-standing customer, a captain you like, asks you to put his private bank details on a supplier's credit note.

No. Credit must go to the customer's account, not to an individual. This is a request to move money outside the books. Decline, and report it.

Quiz

Answer True or False. Answers follow.

1. A commission is always legal if the price to the client is unchanged.
2. A discount shown on the client's invoice is allowed.
3. Asking for a commission is not an offence unless it is paid.
4. A small gift is always acceptable because it is small.
5. If my manager tells me to pay a commission, I may do it.
6. A payment disguised on an invoice as "consultancy" is not a bribe.
7. If I decline a request for commission, I should still record it.
8. If everyone in the market does it, it is legal.
9. A commission written into the contract and known to the client may be lawful.
10. I can ask an agent to pay someone for me, as long as I do not do it myself.
11. I must report a request to pay a bribe even if I refused it.
12. Nobody can be punished at work for refusing to break this policy.

Answers. 1 False. 2 True. 3 False (in most countries the request alone is an offence). 4 False (it depends on whether it is linked to a decision, and who it is for). 5 False. 6 False. 7 True. 8 False. 9 True (and it is the client's knowledge that makes it so). 10 False. 11 True. 12 True.

Pass mark: 10 out of 12. Anyone who scores lower is taken through the answers and re-tested.

Attendance sheet

Date	Name	Position	Score	Signature

Trainer: ____________ Next session due: ________

General information, not legal advice.