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...
1 Anti-bribery—short form—pro-customer Bribery Laws means the Bribery Act 2010 [and associated guidance published by the Secretary of State for Justice under the Bribery...
• 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 give rise to an...
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...
Summary The Bribery Act 2010 (BA 2010) came into force on 1 July 2011. BA 2010 applies to any business incorporated or trading in the UK and covers bribery committed on...
From [[insert job title], ][name] Bribery and corruption remain a major issue in world trade, despite the many dedicated efforts to prevent them. As many of you will...
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...
Is risk assessment overseen at the highest level in the company? In order to show top level commitment to anti-bribery measures, a company officer or Board member should...
The Bribery Act 2010 (BA 2010) was passed to ensure the UK’s compliance with the Organisation for Economic Co-operation and Development's (OECD) Convention on Combating...
All commissions constitute the giving of a financial advantage, although they will not necessarily be bribes. Commissions may be facilitation payments, where the...