Anti-Bribery & Anti-Corruption Training Template and Checklist
A ready-to-run ABAC program and the rollout checklist to go with it. Train by risk, then see which high-exposure teams are actually covered.
Reviewed by Abhijit Rao, AVP & Business Head, India
- A seven-module ABAC program, with audience and coverage for each
- A rollout checklist mapped to your ABAC policy and risk assessment
- A risk coverage matrix that shows where high-exposure teams are thin
- An annual refresher and third-party due-diligence cadence
What is inside
- A seven-module ABAC program, with audience and required coverage for each session.
- A 10-point rollout checklist you can map to your ABAC policy and risk assessment and mark off as you go.
- A risk coverage matrix that scores each team by exposure and shows where high-risk teams are thin.
- An annual refresher and third-party due-diligence cadence so controls stay live.
Who it is for
Anyone who has to plan what people learn, and answer for whether it landed.
- L&D and training teams
- People managers and team leads
- Heads of function and department
- HR business partners
- Compliance and risk teams
- Onboarding and enablement teams
- Operations and delivery leads
- COOs and HR directors
How to use this template in 4 steps
- Pick your format. Download the PDF to share, the Word file to edit, or the Excel file to work in live. All three are free.
- Make it yours. Adapt the sections, fields and wording to your team, roles and process so it fits how you actually work.
- Put it to work. Fill it in, circulate it to stakeholders for sign-off, or roll it out to your team.
- Track and improve. Review it on a set cadence and refine it as your goals, roles and priorities change.
What is inside
- A seven-module ABAC program, with audience and required coverage for each session.
- A 10-point rollout checklist you can map to your ABAC policy and risk assessment and mark off as you go.
- A risk coverage matrix that scores each team by exposure and shows where high-risk teams are thin.
- An annual refresher and third-party due-diligence cadence so controls stay live.
This is practitioner guidance, not legal advice. Anti-bribery law differs sharply by jurisdiction, and facilitation payments are treated differently under different regimes. Adapt the modules and checklist to your own policy and have your legal or compliance team confirm your obligations.
The training program template
Seven modules covering the policy, the high-risk activities and the response system. Run the core set for all staff, then use the deep-dive and refresher for high-exposure roles through the year.
| Module | Audience | Duration | What it must cover |
|---|---|---|---|
| 1. What bribery and corruption are | All staff | 20 min | Bribery, kickbacks and corruption defined, active and passive, and that it applies in every market. |
| 2. Gifts, hospitality and expenses | All staff | 25 min | Thresholds, what to refuse, timing around decisions, and how to record what is offered or accepted. |
| 3. Facilitation payments | All staff | 20 min | What a facilitation payment is, why it is prohibited under most regimes, and what to do when one is demanded. |
| 4. Third-party and agent risk | High-risk roles | 40 min | Due diligence on agents, distributors and intermediaries, contract clauses, and paying only for real services. |
| 5. Red flags | High-risk roles | 30 min | Unusual commissions, vague invoices, shell entities, cash demands, and pressure to bypass a control. |
| 6. Reporting and non-retaliation | All staff | 15 min | Every reporting channel, what happens next, confidentiality and the anti-retaliation commitment. |
| 7. Annual refresher | All staff | 20 min | Policy updates, a recent anonymised case, and a short knowledge check for evidence. |
Delivering the refresher and knowledge check through an LMS gives you dated completion per person and per risk tier, the evidence internal audit or a regulator asks for when testing your ABAC program.
The rollout checklist
Ten steps to get ABAC training live and risk-ranked. Tick items to track your own progress, it stays in this browser. The download has the same list with an owner column.
- ABAC policy published and attestation recordedPolicyAnnual
- Bribery risk assessment used to risk-rank rolesRisk assessmentAnnual
- Gifts and hospitality register live and monitoredGiftsOngoing
- Facilitation-payment prohibition communicatedPolicyOngoing
- Third-party due diligence process in placeThird partiesPer onboarding
- High-risk roles given the third-party and red-flags deep diveRisk-basedAnnual
- Reporting channel published, including an external routeReportingOngoing
- Completion tracked by role and risk tier, not just company-wideGovernanceOngoing
- Annual refresher and knowledge check completedGovernanceAnnual
- Red flags and register entries reviewed for follow-upGovernanceQuarterly
The most common gap is risk-ranking. A flat company-wide rollout can show 90 percent completion while the sales and procurement teams that actually face bribery risk sit in the untrained 10 percent.
Risk coverage at a glance
The checklist tells you what is missing overall. This matrix tells you which high-exposure teams are behind. Score each team on the five areas that carry the most bribery risk. In Excel the coverage and gaps calculate as you type.
| Team | People | Policy attested | Gifts | Facilitation | Third parties | Red flags | Ready |
|---|---|---|---|---|---|---|---|
| Compliance | 25 | 2 | 2 | 2 | 2 | 2 | 100% |
| Procurement | 45 | 2 | 1 | 1 | 2 | 1 | 70% |
| Field sales | 130 | 1 | 1 | 0 | 1 | 0 | 30% |
| Finance | 60 | 2 | 2 | 1 | 1 | 1 | 70% |
| Operations | 150 | 1 | 1 | 1 | 0 | 1 | 40% |
| Coverage at required | 60% | 40% | 20% | 40% | 20% | 62% |
Field sales is the exposure here: no facilitation-payment or red-flags training in the team most likely to be asked for a bribe to close a deal or clear a shipment.
The annual ABAC calendar
| Timing | Action | Owner |
|---|---|---|
| On joining | Core modules and policy attestation in the first week, recorded. | Compliance and L&D |
| On moving into a high-risk role | Third-party and red-flags deep dive before the role starts. | Compliance |
| Per third-party onboarding | Due diligence completed and the owner refreshed on red flags. | Procurement and compliance |
| Annual, all staff | Refresher and knowledge check, tracked by risk tier. | Compliance and L&D |
| Quarterly | Review gifts and hospitality register and any red flags raised. | Compliance |
| After any case | Targeted refresher for the team and market involved. | Compliance |
How to run it
- Risk-rank roles before you train
Use your bribery risk assessment to find the roles that touch third parties, permits, tenders and payments. Train those deepest.
- Attest the policy, do not just circulate it
Get a recorded confirmation that each person has read and understood the ABAC policy, including the facilitation-payment rule.
- Train third-party owners on due diligence
Anyone who onboards or pays an agent, distributor or intermediary needs the red-flags and due-diligence module in depth.
- Track completion by role and risk tier
Roll it up so an untrained high-risk team is visible before an incident, not after.
- Make the reporting route obvious
Publish every channel, including one outside the line manager, and reinforce non-retaliation.
- Review coverage and red flags quarterly
Completion by risk tier, open gifts and hospitality entries, and any third-party red flags raised.
Frontline teams reach 45 percent-plus completion on Disprz when training is delivered in short, mobile modules in the local language, the format this program is built for.
Common mistakes this pack prevents
- A flat, everyone-the-same rollout that ignores where bribery risk actually sits.
- A company-wide completion number that hides the untrained sales and procurement teams.
- Skipping third parties, when agents and intermediaries are the classic route for a bribe.
- Treating facilitation payments as a grey area instead of stating the rule clearly.
- No dated records by risk tier, so there is nothing to show internal audit or a regulator.
Which format should you use?
| Format | Best for | What is inside | Editable | Size |
|---|---|---|---|---|
| Sharing and print | The full template, formatted to print or circulate | No | 55 KB | |
| Word | Editing the wording | Every section as editable text you can adapt | Yes | 86 KB |
| Excel | Filling it in live | The grid and fields set up as a working spreadsheet | Yes | 66 KB |
Questions people ask
Is anti-bribery training mandatory?
How often should ABAC training happen?
Why risk-rank instead of training everyone the same?
Can I adapt the modules and checklist?
Do I have to fill the form three times?
ABAC training only counts if the high-risk teams finish it and you can prove it. That is the part we run.
Bring your teams to a 30-minute working session. We will show how Disprz delivers ABAC training in short mobile modules in the local language, risk-ranked by role, and rolls completion up by tier, so your next audit or regulator request is a two-minute export.