Bribery, modern slavery, tax evasion and fraud

This Overview provides a summary of the materials in the subtopic Bribery, modern slavery, tax evasion and fraud.

Bribery Act 2010

The Bribery Act 2010 (BA 2010) applies to individuals and to any business that is incorporated or trades in the UK. It covers bribery committed by the organisation, or on its behalf, anywhere in the world.

A bribe is defined as:

  1. a 'financial or other advantage' offered, promised, requested or given

  2. to induce a person to perform a relevant function or activity improperly, or

  3. to reward them for doing so

'Financial or other advantage' is not defined, but is likely to include cash or cash equivalent, gifts, hospitality and entertainment, preferential treatment in a tendering process, etc. The timing of the bribe is irrelevant and payments made after the relevant event will still be caught, as will bribes that are given or received unknowingly. It is not necessary for the individual or organisation actually to receive any benefit as a result of the bribe for liability to arise.

BA 2010 has significant implications in the employment context.

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Detailed list of Home Office’s Sponsor Guidance changes of 6 March 2026

Immigration analysis: On 6 March 2026, the Home Office issued new versions of each of the three principal Worker and Temporary Worker Sponsor Guidance documents, as well as of other Sponsor Guidance documents including Appendix D (on retaining documents) and the Sponsor a Skilled Worker guidance. We have set out below a detailed list of all of the substantive changes, as well as other wording changes which the Home Office appears to have made to focus sponsors’ minds on recent operational concerns, in light of the current significant increase in compliance checks and enforcement (eg around salary underpayment). One important change is the replacement of the ‘genuine vacancy’ concept with the newly defined term ‘eligible role’, now contained in a new standalone glossary document. The new four-limbed definition embeds skill, salary and route requirements, compliance with wider employment law, and proportionality to the sponsor’s business model into a continuing test that must be met throughout sponsorship. Other operational-related changes include around illegal working requirements, and reinforcing the importance of Certificate of Sponsorship details matching the work actually undertaken (or reporting permitted changes). The wording around the standard of proof for the enforcement threshold in some cases has also been amended to ‘reasonable suspicion’, presumably as an attempt to expand the Home Office’s discretion to refuse, suspend or revoke licences. Other suitability/compliance amendments relate to concerns about dishonesty, salary inflation or risks to the integrity of the sponsorship system. At the same time, the guidance emphasises that participation in the sponsorship scheme (now formally termed a ‘scheme’) is voluntary and that a licence is granted and held at the Home Office’s discretion. There is also an increased focus on worker welfare and compliance with wider UK law, including a new requirement to inform sponsored workers of their employment rights and retain evidence of having done so. It had been anticipated that further guidance would be included on when and how employers are permitted to ‘claw back’ some immigration costs in circumstances where a sponsored worker leaves their employment early, but there were no more changes made on this aspect in the new guidance.

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