The purpose of this Practice Note is to provide a general understanding of the offences under section 1, 2 and 6 of the Bribery Act 2010 (BA 2010). It does not cover the...
An agent is a person who performs services for or on behalf of a commercial organisation. The use of agents will principally create risk under the Bribery Act 2010, s 7...
Charitable and political donations can give rise to higher risks of bribery and corruption. They can be (or be seen to be) bribes in disguise. This Practice Note sets out...
• Has your company got a clear and forthright code of ethics which explicitly refers to a zero tolerance of bribery and corruption? This code of ethics should reflect the...
A civil recovery order (CRO) is an order available to recover the proceeds of crime through action in the High Court, rather than the criminal court, and is governed by...
Brexit impact—public procurement The UK public procurement regime derives from EU public procurement laws, and is therefore impacted by the UK’s withdrawal from the EU....
• Does the company have a due diligence policy which covers all parties to a business relationship, including the company's supply chain, agents, joint venture or similar...
• Any agent or representative of a business should be subject to due diligence • The company will have to make their own inquiries supplementing any information with...
Facilitating the performance of a duty by public officials Facilitation payments, also known as facilitating or grease payments, are generally small amounts of money paid...
Corporate criminal liability for bribery—section 7 of the Bribery Act 2010 This offence can only be committed by relevant commercial organisations (RCOs), not...
Required document or actionYes/NoComment/action required Do you have a public, clear and forthright code of ethics and/or anti-bribery and corruption policy which...
Almost every business and everyone involved in the carrying on of a trade incorporates an element of hospitality to existing or potential business partners in some form...
Businesses and their employees must be alert to indicators of corruption. The following checklist identifies indicators of corruption which would normally...
The following questions and issues should be at the forefront of a lawyer’s mind when advising in relation to an internal investigation on suspicion of bribery. This...
The nature of the offence This Practice Note explains the rules relating to the jurisdiction to try allegations of bribery under the Bribery Act 2010, which depends on...
Offset arrangements arise where an additional investment, payment or other industrial, commercial or economic benefit is offered or required as part of an organisation’s...