Direct answer: A procurement bribery and integrity-compliance page is not the slogan "no gifts". The page should state: which conduct may amount to commercial bribery (kickbacks, facilitation payments, cash/gift cards, gifts, hospitality, travel, entertainment, sponsorship/donations, consultancy/service/introducer fees, relatives/related parties, deferred payment/options, bid compensation); the applicable law and consequences (the Anti-Unfair Competition Law, revised on 27 June 2025 and effective 15 October 2025, Article 8 prohibits bribery of the counterparty's staff, units/individuals entrusted by the counterparty, and units/individuals using authority or influence over the transaction; Article 24 imposes fines of RMB 100,000–1,000,000, or RMB 1,000,000–5,000,000 with possible licence revocation in serious cases, and the legal representative, principal person in charge and directly responsible persons may be personally fined; Criminal Law Articles 163 and 164 cover non-state-staff bribery); gift/hospitality/travel boundaries and approval/registration; third-party/agent/consultant due diligence and payment controls; conflict-of-interest and related-party declarations; whistleblowing, investigation, discipline and remediation; contract integrity clauses and a supplier integrity programme; public boundary. This article is current to 2026-11-11 and is a summary of public rules and page method, not legal/compliance/audit advice; the law, judicial determination and company policies control.
This article is for procurement, legal, compliance, finance, internal audit, HR and website teams at equipment, electronics, automotive-parts, medical-device, hardware, chemical, packaging and export manufacturers in Changzhou and nearby. It covers how to write and accept a procurement bribery and integrity-compliance page. The usual gap is "no gifts only, no kickback/third-party/relative analysis, no gift/hospitality limits, consultancy without deliverables, no conflict declaration, no reporting channel, no investigation procedure, no contract clause", ending with a page that only says "clean procurement, no bribery", while supplier reports/internal audits/regulator investigations/customer compliance reviews still disagree.
Commercial bribery is not just cash: benefits in kind, third-party fees, relatives and "deferred" rewards count; gifts and hospitality need limits, approval and a register, and discounts/commissions must be explicit and truthfully recorded; reporting, investigation, discipline, remediation and contract clauses must work, not just an "integrity undertaking".
How does this page relate to fraud/bid-rigging, supplier code of conduct, negotiation, supplier cooperation and internal audit pages?
The integrity page answers "what is commercial bribery, where are the gift/hospitality limits, how to manage third parties and conflicts, how to report/investigate, and how contracts constrain it"; the fraud/bid-rigging page answers "how to identify cover bidding, accompanying bids and data anomalies"; the supplier code/responsible-sourcing page answers "labour, safety, environment and ethics requirements"; the negotiation/cost-model page answers "BATNA, cost breakdown and concessions"; the supplier cooperation/announcement page answers "onboarding, RFQ, payment, acceptance and integrity reporting"; the internal audit page answers "audit plan, sampling, evidence and remediation". The integrity page is the main page for "bribery and conflicts of interest" and cannot be replaced by a code of conduct or audit page.
Common breaks: "no kickbacks" only; no gift/hospitality thresholds or approval; consultancy without deliverables; no relative/related-party declaration; supplier payments to personal accounts; reporting channel only on a poster; investigation without independence or evidence; no discipline/remediation; no contract clause. The page separates "conduct—law—gifts/hospitality—third parties—conflicts—reporting/investigation—contract" so procurement/legal/compliance/finance/audit/HR share one vocabulary.
| Page | Question it answers | Key content | Cannot replace |
|---|---|---|---|
| Integrity compliance | Bribery/gifts/third parties/conflicts/investigation | Conduct, law, process, contract | Fraud detection |
| Fraud/bid-rigging | Cover bidding/accompanying bids/data anomalies | Red flags, data, investigation | Integrity programme |
| Supplier code | Labour/safety/environment/ethics | Code, audit, remediation | Bribery investigation |
| Negotiation/cost model | BATNA/cost/concessions | Preparation, model, register | Integrity boundary |
| Supplier cooperation/announcement | Onboarding/RFQ/payment/acceptance | Process, reporting entry | Investigation procedure |
| Internal audit | Plan/sampling/evidence/remediation | Workpapers, findings, accountability | Day-to-day compliance |
Page relationships are editorial; the law, company policies and judicial determination control.
What forms of procurement bribery exist, and what are the red flags?
Forms include: cash/transfers/gift cards/gifts; kickbacks/facilitation payments/"service fees"; banquets, travel, entertainment, gym/club memberships; sponsorship, donations, academic/association fees; consultancy, service, introducer and marketing fees; free or discounted home renovation, vehicles, memberships, children's education/employment; relatives/specific related persons holding shares or positions; supplier payment of personal expenses; deferred/option/ post-resignation rewards; bid compensation/cover-bidding benefits; benefits disguised as "samples/trials/loans". Red flags: prices clearly above market; strained sole-source justification; frequent changes/add-ons; concentrated suppliers with many complaints; third parties paid without substantive services; payments to personal/related accounts; unusual employee-supplier contact; a supplier suddenly winning/renewing; an employee's lifestyle inconsistent with income. Red flags are not conclusions; verify through procedure.
Acceptance checks: conduct list; benefits in kind; third-party fees; relatives/related parties; deferred rewards; red flags; verification; records. Common gaps: cash only; no benefits in kind; no third-party checks; no relative declaration; red flag as conclusion; no records.
| Form | What to write | Evidence | Common gap |
|---|---|---|---|
| Cash/cards/gifts | Amount/recipient/time/purpose | Register/voucher | "No gifts" only |
| Kickbacks | Rate/base/payment path | Contract/bank flow | Not identified |
| Hospitality/travel/entertainment | Limits/approval/accompanying | Request/invoice | No limits |
| Sponsorship/donation | Recipient/purpose/benefit | Agreement/receipt | Disguised benefit |
| Consultancy/service/introducer | Scope/deliverable/rate | Contract/deliverable | No substantive service |
| Relatives/related parties | Relationship/shareholding/position/recusal | Declaration | No declaration |
| Deferred/options | Post-resignation/future reward | Agreement/record | Ignored |
| Bid compensation | Cover bidding/compensation | Bid/communication | Treated as normal |
Forms and red flags are editorial; the law, evidence and judicial determination control, and a red flag is not a bribery conclusion.
What should the 2025 Anti-Unfair Competition Law and Criminal Law mean for the page?
The Anti-Unfair Competition Law was revised for the second time on 27 June 2025 and took effect on 15 October 2025. Article 8 prohibits an operator from bribing, by giving property or other means, three categories: the counterparty's staff; units or individuals entrusted by the counterparty to handle relevant matters; and units or individuals using authority or influence over the transaction; it also states that those recipients must not accept bribes; discounts and commissions may be paid explicitly but must be truthfully recorded, and the recipient must also record them truthfully; bribery by an operator's staff is in principle attributed to the operator unless it proves the conduct was unrelated to obtaining transaction opportunities or competitive advantage. Article 24: confiscate illegal gains and fine RMB 100,000–1,000,000; in serious cases RMB 1,000,000–5,000,000 and possible licence revocation; the legal representative, principal person in charge and directly responsible persons who bear personal responsibility, and individuals receiving bribes, may be fined up to RMB 1,000,000. Article 33: administrative penalties are recorded in the credit record and publicised. Criminal Law Articles 163 (non-state-staff bribery) and 164 (bribing non-state staff), unit crime, and the 2008 Supreme People's Court/Supreme People's Procuratorate Opinion should be read together: property includes money, goods and calculable benefits in kind (renovation, membership cards, travel); bid evaluation committee, competitive-negotiation and inquiry group members may be treated under Article 163; bribery versus gifts is judged by background, value, timing, request and use of position.
Acceptance checks: applicable law; three categories; recipient liability; discount/commission recording; employee attribution; administrative fines/personal liability/credit record; criminal offences; benefits in kind; bid/negotiation personnel; gift distinction. Common gaps: "no bribery" only; unaware recipients are also liable; off-book discounts; separating employee conduct; administrative only; cash only.
| Rule | Key point | Basis | Common gap |
|---|---|---|---|
| Recipients | Counterparty staff/entrusted/influential | AUCL Art. 8 | Supplier only |
| Recipient liability | Recipients must not accept bribes | AUCL Art. 8 | Buyer only |
| Discounts/commissions | Explicit and truthfully recorded | AUCL Art. 8 | Off-book kickback |
| Employee conduct | Attributed to operator in principle | AUCL Art. 8 | Blame the individual |
| Administrative penalty | RMB 0.1–1m; serious 1–5m + licence | AUCL Art. 24 | Underestimate |
| Personal liability | Legal rep/principal/directly responsible | AUCL Art. 24 | Company only |
| Criminal liability | Arts. 163/164; unit crime dual punishment | Criminal Law | Administrative only |
| Benefits in kind | Renovation/membership/travel etc. | 2008 Opinion | Cash only |
Legal points are editorial; the law, judicial interpretations and judicial determination control.
How should gifts, hospitality, travel and festive exchanges be bounded?
Policy at minimum: prohibit cash/gift cards/securities/valuables; set value and annual cumulative limits, prior approval and registration for gifts/souvenirs; set per-head limits, frequency, number of hosts, business purpose and invoice requirements for banquets/hospitality; state who bears travel/transport/accommodation and prohibit suppliers from bearing private/family expenses; travel, entertainment, gym/club and event tickets are normally prohibited or strictly approved; apply stricter rules to public officials/state-owned-enterprise/customer procurement staff to avoid influencing official duties; require declaration/refusal/return for festivals, weddings/funerals, birthdays and other sensitive occasions; register and hand in anything that cannot be refused; prohibit facilitation payments; review supplier sponsorship/donations for recipient, purpose, benefit and approval. The gift register must answer "who gave, to whom, what, how much, why and how handled".
Acceptance checks: prohibited items; value/cumulative limits; prior approval; register; hosts/per-head; travel bearer; public officials; sensitive occasions; hand-in/return; sponsorship; records. Common gaps: "no gifts" only; no amount; retrospective approval; supplier-paid travel; no festival declaration; sponsorship as advertising.
| Scenario | What to write | Evidence | Common gap |
|---|---|---|---|
| Cash/cards/securities | Prohibited/hand in | Policy/register | Slogan only |
| Gifts/souvenirs | Value/cumulative/approval/register | Request/register | No limit |
| Banquet/hospitality | Per-head/frequency/hosts/purpose | Request/invoice | No standard |
| Travel/accommodation | Who pays/no private expenses | Claim/approval | Supplier pays |
| Travel/entertainment | Normally prohibited/strict approval | Approval | Treated as perk |
| Public officials | Stricter/avoid influencing duties | Approval/record | Same as customers |
| Festivals/weddings | Declare/refuse/return | Declaration | No declaration |
| Sponsorship/donation | Recipient/purpose/benefit/approval | Agreement/receipt | Disguised benefit |
Gift/hospitality policy is editorial; company policies, industry rules and applicable law control.
How should third parties, agents, consultants and introducers be vetted and paid?
At minimum: business necessity (why a third party, can we buy directly); background/ownership/beneficial owner/address/qualification; whether connected to employees/customers/public officials; service scope/deliverables; whether fees/commissions are market-comparable and linked to winning/orders; subcontracted/re-delegated work; payment path (corporate account, matching contract/invoice, no personal/third-country accounts); contract (compliance undertaking, audit right, books and records, subcontract consent, termination/indemnity, training); acceptance of deliverables before payment; ongoing monitoring (unusual payments, cash, political donations/sponsorship, frequent supplier changes). Red flags: no office/employees, newly established, shareholder names matching employees, unverifiable deliverables, abnormally high fees, requests for cash/third-party accounts, promises to "handle" customers/tenders. A third party is not a firewall; the principal may still be liable.
Acceptance checks: necessity; background/beneficial owner; connections; service/deliverables; fees; subcontracting; payment path; contract; acceptance; monitoring. Common gaps: no necessity; no shareholder check; no deliverables; no fee benchmark; personal account; no compliance clause; no monitoring.
| Step | What to write | Evidence | Common gap |
|---|---|---|---|
| Necessity | Why/why not direct | Request | No need |
| Background | Ownership/beneficial owner/address/qualification | Due diligence | No shareholder check |
| Connections | Employees/customers/public officials | Declaration/query | Not identified |
| Service/deliverables | Scope/deliverable/acceptance | Contract/deliverable | No deliverable |
| Fees | Market benchmark/linked to orders | Quotation/analysis | Abnormally high |
| Subcontracting | Consent/list/liability | Contract | Layered subcontracting |
| Payment | Corporate/contract/invoice match | Bank flow | Personal account |
| Monitoring | Unusual payments/sponsorship/changes | Record | No monitoring |
Third-party due diligence is editorial; company policies, contracts and applicable law control.
How should conflicts of interest, related parties and personnel dealings be accepted?
At minimum: annual conflict-of-interest declarations for procurement/quality/R&D/finance and other key roles (relatives, shareholding, outside positions, consulting, gifts); supplier ownership/beneficial-owner/director-senior-manager screening against employees; related-party identification, approval, arm's-length pricing and disclosure; recusal in evaluation/negotiation/acceptance/payment; employees and relatives working for/holding shares in suppliers; cooling-off and contact management for former public officials/former customer employees; approval for hiring supplier personnel/relatives; declaration of supplier banquets/gifts/travel; optional tracking of former employees' destinations; whistleblower protection. A conflict is not guilt: declare, assess, recuse and record; concealment is the issue.
Acceptance checks: declaration scope/frequency; supplier relationship screening; related-party approval/pricing; recusal; positions/shareholding; cooling-off; hiring; gift declaration; records. Common gaps: no declaration; no ownership check; no related-party approval; no recusal; no former-official management; no hiring approval.
| Item | What to write | Evidence | Common gap |
|---|---|---|---|
| Annual declaration | Relatives/shareholding/positions/consulting | Form | No declaration |
| Supplier relationship | Ownership/beneficial owner/directors | Screening | No ownership check |
| Related-party transaction | Identify/approve/price/disclose | Approval | No approval |
| Recusal | Evaluation/negotiation/acceptance/payment | Record | No recusal |
| Positions/shareholding | Employees/relatives in suppliers | Declaration/query | Not identified |
| Cooling-off | Former public officials/customer staff | Policy | No management |
| Hiring | Supplier personnel/relatives approval | Approval | No approval |
| Gifts | Declare/register/handle | Register | No register |
Conflict management is editorial; company policies, labour rules and applicable law control.
How should reporting, investigation, discipline and remediation be accepted?
At minimum: multiple reporting channels (phone/email/platform/letter/in person), anonymous reporting allowed, confidentiality and non-retaliation stated; triage/intake (matter, amount, persons, evidence, timing); independent investigation (avoid the subject/related persons), two-person, records, evidence preservation (emails/contracts/bank flows/chats/recordings lawfully obtained); interviews/right to respond; legal/external advisers where needed; interim measures (suspension/payment hold/supplier suspension); findings (substantiated/partly/unsubstantiated/unable to verify); discipline (disciplinary/recovery/referral); supplier action (warning/suspension/exit/blacklist); remediation (policy/process/training/system control); review and disclosure (internal/necessary external); whistleblower protection. Avoid "conclusion first, evidence later" and "internal digestion".
Acceptance checks: channels; anonymity/confidentiality; triage; independence; evidence; interview/response; interim measures; findings; discipline; supplier action; remediation; review; protection. Common gaps: email only; no independence; no evidence preservation; no response; no supplier action; no remediation; retaliation.
| Step | What to write | Evidence | Common gap |
|---|---|---|---|
| Channels | Multiple/anonymous/confidential | Entry/record | Email only |
| Triage | Matter/amount/persons/timing | Register | No triage |
| Independence | Recusal/two-person/external | Appointment | Self-investigation |
| Evidence | Email/contract/bank flow/chat | Workpapers | No preservation |
| Interview/response | Statement/response/signature | Minutes | No response |
| Interim measures | Suspension/payment hold/supplier hold | Decision | Keep paying |
| Findings/discipline | Substantiated/partly/unsubstantiated/unable | Report | Internal digestion |
| Remediation/review | Policy/process/training/system | Record | No remediation |
Investigation procedure is editorial; the law, company policies and judicial requirements control, including lawful evidence collection and employee/supplier rights.
How should contract integrity clauses and a supplier integrity programme be written?
Contract at minimum: supplier undertakes to comply with anti-corruption/anti-bribery law and the buyer's integrity policy; no kickbacks, gifts, hospitality, travel, employment or other benefits to buyer employees/relatives/entrusted persons; flow-down to subcontractors/agents; true and complete books/records; buyer audit right (notice, scope, confidentiality, cost); supplier cooperation with investigations; on breach, payment hold/termination/indemnity/blacklisting; reporting channel; training/certification (optional); continuing undertaking during the contract and for a period after termination. Supplier programme: integrity screening at onboarding, integrity undertaking/agreement, annual training, risk grading (category/country/amount/agent), audit/questionnaire, performance/exit. Clauses must be enforceable, not just "no bribery" without audit/termination/indemnity.
Acceptance checks: compliance undertaking; prohibited benefits; flow-down; books; audit right; investigation cooperation; breach consequences; reporting; training; risk grading. Common gaps: undertaking only; no audit right; no termination; no indemnity; no flow-down; no training.
| Clause | What to write | Evidence | Common gap |
|---|---|---|---|
| Compliance undertaking | Law/buyer policy | Contract | One sentence |
| Prohibited benefits | Kickbacks/gifts/hospitality/employment | Contract | Kickbacks only |
| Flow-down | Subcontractors/agents/intermediaries | Contract | No flow-down |
| Books/records | True/complete/auditable | Contract | No requirement |
| Audit right | Scope/notice/confidentiality/cost | Contract | No audit |
| Investigation cooperation | Interviews/documents/site | Contract | No cooperation |
| Breach consequences | Hold/terminate/indemnify/blacklist | Contract | No consequence |
| Training/grading | Annual/risk-based | Record | No training |
Contract terms are editorial; the contract, applicable law and judicial/arbitral determination control.
How should the website page be written, and what must not be published?
Suggested sections: (1) integrity policy/scope; (2) bribery forms and prohibitions; (3) gift/hospitality/travel boundaries; (4) third-party/agent/consultant management; (5) conflict-of-interest/related-party declaration; (6) reporting channel/investigation/protection; (7) contract clauses/supplier programme; (8) contact window and update date. The public page explains "policy, boundaries, process, channel, consequences" and does not publish specific reporters/subjects/employee information, investigation details, supplier lists/contracts/prices, customer names, undisclosed penalties/settlements. The English page should use consistent terms (bribery, kickback, facilitation payment, conflict of interest, third-party due diligence, whistleblowing, investigation, remediation) and state the cut-off date. Do not turn the page into an absolute "we never have corruption" promise.
The page should let suppliers/employees/customers know "what is prohibited, how to declare gifts/hospitality, how to report suspicions, how investigation works, and what the consequences are", while protecting reporters and personal privacy. Without policy/process evidence, do not write "zero corruption/100% compliant".
Go-live acceptance checklist
Ten checks: policy/scope; bribery forms/prohibitions; gifts/hospitality/travel; third-party due diligence; conflicts/related parties; reporting channel/protection; investigation/discipline/remediation; contract clauses/supplier programme; training/communication; public boundary. Each needs evidence and a review date. The pass standard is not "an integrity undertaking exists", but that procurement/legal/compliance/finance/audit/HR can judge what is prohibited, how to declare, how to report, how to investigate and what the consequences are.
Before go-live, run a tabletop exercise on a real (redacted) scenario: supplier gift → register/return; third-party consultancy → necessity/deliverable/payment; employee relative shareholding → declaration/recusal; report → intake/investigation/discipline/remediation, to see whether the page and process work.
| Check | Pass standard | Evidence | If failed |
|---|---|---|---|
| Policy/scope | Persons/conduct/application | Policy | Add policy |
| Forms/prohibitions | Cash/kickbacks/benefits/deferred | List | Add list |
| Gifts/hospitality | Limits/approval/register | Register | Add limits |
| Third parties | Due diligence/deliverable/payment | File | Add due diligence |
| Conflicts | Declaration/recusal/related party | Form | Add declaration |
| Reporting/protection | Channels/anonymous/confidential | Entry | Add channel |
| Investigation/remediation | Independent/evidence/discipline/review | Report | Add procedure |
| Contract/supplier | Undertaking/audit/termination/indemnity | Contract | Add clause |
| Training/communication | Annual/new joiner/supplier | Record | Add training |
| Public boundary | No reporters/investigations/lists | Page | Take down |
The acceptance list is editorial; the law, company policies and judicial determination control.
Who should read it, who should not, and what decisions does it support?
For procurement, legal, compliance, finance, internal audit, HR and website teams at equipment, electronics, automotive-parts, medical-device, hardware, chemical, packaging and export manufacturers in Changzhou and nearby; also for companies handling "no gifts only, no kickback/third-party/relative analysis, no gift/hospitality limits, no reporting channel, no investigation procedure, no contract clause". Not for teams without procurement/supplier management, or that want one page to replace legal/compliance/audit advice.
Read it if: building an integrity page; "no bribery" only; no benefits in kind; no third-party checks; no relative declaration; no gift limits; no reporting procedure. Not suitable if: treating integrity as a slogan; treating a third party as a firewall; treating gifts as trivial; treating the page as a legal/compliance conclusion. Supports: bribery forms, gifts/hospitality, third parties, conflicts, reporting/investigation, contract clauses and public-boundary self-checks.
FAQ
What is the difference between the integrity page, the fraud/bid-rigging page and the supplier code page?
The integrity page answers "what is commercial bribery, where are the gift/hospitality limits, how to manage third parties/conflicts, how to report/investigate, and how contracts constrain it"; the fraud page answers "how to identify cover bidding, accompanying bids and data anomalies"; the code page answers "labour, safety, environment and ethics requirements". They complement each other; the integrity page is the main page for bribery and conflicts of interest and cannot be replaced by a code or audit page.
How do kickbacks, gifts, hospitality and normal business courtesy differ?
Look at whether the purpose is to obtain transaction opportunities/competitive advantage, whether it violates law/policy, whether it improperly influences decisions, whether it is truthfully recorded, and whether it targets counterparty staff/entrusted persons/influential persons. Normal, open, reasonably valued gifts/working meals approved and registered under policy carry lower risk; cash/gift cards/valuables, off-book discounts, supplier-paid private/family travel, travel/entertainment, deferred/option rewards, and relatives' positions/shareholding carry higher risk. Judge by background, value, timing, request and use of position; consult a lawyer where needed.
What should an employee do if a supplier offers a gift?
Follow company policy: refuse in person where possible and explain the policy; where refusal is impossible, register and hand in the gift/cash/gift card and do not use or pass it on; declare or refuse supplier banquets/travel/entertainment in advance; cash/cards/securities are normally prohibited and must be registered/handed in; report proactively to compliance/HR/internal audit rather than "accept first, report later". The company must protect reporters and prohibit retaliation.
Can a third party/agent/consultant isolate the risk?
No. The principal may still be liable for the third party's bribery; a third party is not a firewall. Procurement should check necessity, background/beneficial owner, connections, deliverables, fees, subcontracting, payment path, contract audit rights and ongoing monitoring; reject or escalate third parties with "no substantive service, abnormal fees, requests for cash/personal accounts, or promises to handle customers/tenders".
What changes in the 2025 Anti-Unfair Competition Law should the page cover?
At least: Article 8's three categories of recipients and recipients' liability; discounts/commissions must be explicit and truthfully recorded; employee bribery is in principle attributed to the operator; Article 24 fines of RMB 0.1–1 million, or 1–5 million with possible licence revocation in serious cases, plus personal liability of the legal representative/principal/directly responsible persons; Article 33 credit record and publicity; Article 34 civil, administrative and criminal liability coexist, with civil liability paid first where assets are insufficient. The page should also link to Criminal Law Articles 163/164 and the 2008 Supreme People's Court/Supreme People's Procuratorate Opinion (benefits in kind, bid/negotiation personnel, gift distinction).
What makes reporting and investigation effective?
Multiple channels, anonymity, confidentiality and non-retaliation; triage and intake; independent investigation (recusal of interested persons), two-person, evidence preservation, interviews/right to respond; external lawyers/advisers where needed; interim measures (suspension/payment hold/supplier hold); classified findings; discipline/recovery/referral; supplier action; policy/process/training/system remediation; review and necessary disclosure. Avoid "conclusion first, evidence later" and "internal digestion", and observe lawful evidence collection and employee/supplier rights.
Should the website publish the reporting channel, investigation results and supplier lists?
Publish the reporting channel, confidentiality/non-retaliation commitment, policy scope and contact details; normally do not publish reporters/subjects/employee information, investigation details, supplier lists/contracts/prices, customer names, or undisclosed penalties/settlements. The goal is to let suppliers/employees/customers know the rules and channel, not to disclose individual cases or personal information.
One-sentence takeaway
The procurement bribery and integrity-compliance page on a Changzhou manufacturer's website is not a "no gifts" slogan; it is about turning bribery forms, Anti-Unfair Competition Law/Criminal Law consequences, gift/hospitality boundaries, third-party due diligence, conflict declarations, reporting/investigation, contract clauses and public boundaries into a checkable list, so procurement/legal/compliance/finance/audit/HR can judge what is prohibited, how to declare, how to report, how to investigate and what the consequences are.
Research method and limitations
This article is a summary of public rules and page method, not legal/compliance/audit advice. It uses no unpublished reporter/subject/employee information, investigation details, supplier lists/contracts/prices, customer names or undisclosed penalties; the tables and acceptance items are editorial and not bribery/compliance conclusions. The Anti-Unfair Competition Law (2025 revision), Criminal Law Articles 163/164, the 2008 Supreme People's Court/Supreme People's Procuratorate Opinion, the U.S. FCPA, the UK Bribery Act 2010 and MOF Internal Control Application Guideline No. 7 (Procurement) are public sources; the law, judicial interpretations, regulatory/judicial determination and company policies control. This article does not decide whether any specific conduct is bribery, and does not promise "zero corruption/100% compliant"; companies should set rules item by item based on business, jurisdiction, customers and applicable law.
Sources and basis
Current to 2026-11-11; the official pages below control.
- Anti-Unfair Competition Law of the PRC (second revision on 27 June 2025; effective 15 October 2025): National People's Congress. Article 8 bribery recipients/recipient liability/discounts and commissions/employee attribution; Article 24 administrative penalties and personal liability; Article 33 credit record; used for boundaries and consequences.
- Criminal Law Articles 163 (non-state-staff bribery) and 164 (bribing non-state staff) and the 2008 Supreme People's Court/Supreme People's Procuratorate Opinion on commercial bribery: Supreme People's Procuratorate. Offences, unit crime, property/benefits in kind, bid/negotiation/inquiry personnel, gift distinction; used for criminal-law linkage.
- U.S. Department of Justice, Foreign Corrupt Practices Act (FCPA): DOJ. Bribery of foreign officials, books and records, jurisdictional links; used for export manufacturers' cross-border compliance note.
- UK Bribery Act 2010 (Ministry of Justice guidance): GOV.UK. Bribing/receiving/bribing foreign public officials/failure of commercial organisations to prevent bribery; used for UK-link note.
- MOF Internal Control Application Guideline No. 7 — Procurement (Cai Kuai [2010] No. 11): Linyi Finance Bureau. Supplier selection, contracts, acceptance, payment and records; used for segregation of duties and procurement controls.