The document summarizes the UK Bribery Act 2010. It discusses how the UK ranked 11th but fell to 20th on a corruption index. It then outlines the main provisions of the Act, including prohibiting bribery, influencing public officials, and failing to prevent bribery by associated parties. It also discusses penalties like imprisonment and fines. Finally, it provides guidance on adequate procedures for complying with the Act, such as risk assessment, top-level commitment, due diligence, training, and monitoring.
The most significant changes to insurance law in 110 years came into effect in August 2016. The Insurance Act 2015 makes some fundamental changes to what businesses have to do to ensure that their insurance policies are effective and that their claims are paid in full. This webinar looks at the changes that have been made, what businesses need to do in order to comply with new rules on disclosure and how the new remedies for breach are to be applied. The Act applies to all policies governed by the laws of England, Wales, Scotland and Northern Ireland which are taken out, renewed or varied on or after 12 August 2016. Accordingly, it is essential that all UK businesses have a full understanding of the new rules.
Neill Blundell provides an update of recent bribery activity around the world and discusses whether it is a real issue for business or merely an overstated problem.
Best Practices for Anti-Bribery and Anti-Corruption (ABAC) ComplianceWinston & Strawn LLP
Winston & Strawn hosted a webinar titled “Best Practices for Anti-Bribery and Anti-Corruption (ABAC) Compliance.”
The interactive webinar focused on the following ABAC compliance topics:
- Anti-bribery and anti-corruption authorities
- Essential elements of a comprehensive and effective compliance program
- Implementing your compliance program in real-world scenarios
- Problem management and escalation protocol
The most significant changes to insurance law in 110 years came into effect in August 2016. The Insurance Act 2015 makes some fundamental changes to what businesses have to do to ensure that their insurance policies are effective and that their claims are paid in full. This webinar looks at the changes that have been made, what businesses need to do in order to comply with new rules on disclosure and how the new remedies for breach are to be applied. The Act applies to all policies governed by the laws of England, Wales, Scotland and Northern Ireland which are taken out, renewed or varied on or after 12 August 2016. Accordingly, it is essential that all UK businesses have a full understanding of the new rules.
Neill Blundell provides an update of recent bribery activity around the world and discusses whether it is a real issue for business or merely an overstated problem.
Best Practices for Anti-Bribery and Anti-Corruption (ABAC) ComplianceWinston & Strawn LLP
Winston & Strawn hosted a webinar titled “Best Practices for Anti-Bribery and Anti-Corruption (ABAC) Compliance.”
The interactive webinar focused on the following ABAC compliance topics:
- Anti-bribery and anti-corruption authorities
- Essential elements of a comprehensive and effective compliance program
- Implementing your compliance program in real-world scenarios
- Problem management and escalation protocol
Global business attorney Luis Alcalde presented "Managing International Risks + Corporate Investigations" on Thursday, January 16, at the Schneider Downs' Corporate Corruption + Fraud Seminar.
Luis discussed international corporate investigations involving the Foreign Corrupt Practices Act (FCPA), corporate ethics and other regulatory matters.
Guide to The Bribery Act 2010 by Josiah HincksJosiahHincks
The Bribery Act 2010 came in to force in the UK in July 2011.
It creates criminal offences for individuals who give or receive bribes.
It also creates an offence for Companies and Partnerships who fail to prevent bribery occuring. The fines are unlimited.
This slide show from Josiah Hincks Solicitors in Leicester presents everything you need to know about Bribery, The Bribery Act, and how to ensure your business is compliant.
Visit http://www.josiahhincks.co.uk for more information about our firm of solicitors in Leicester.
Julie Murphy O'Connor and Gearoid Carey provide an overview on Enforcement of Foreign Judgments in Ireland in the 2018 edition of Getting the Deal Through.
The Legal 500: Bribery and Corruption Comparative Guide 2018Matheson Law Firm
Claire McLoughlin and Karen Reynolds, Partners in the Commercial Litigation and Dispute Resolution Department and Co-heads of the Regulatory and Investigations Group, co-author the Ireland chapter for The Legal 500: Bribery and Corruption Comparative Guide 2018.
C-Suite Workshop presented by Stephen Booth and Peter Stewart on 10 April 2019LaraMartinsons
C-Suite Workshop: Modern Slavery, Anti-Bribery & Corruption, Privacy and Whistleblowers presented by Stephen Booth and Peter Stewart at Coleman Greig, Parramatta
Getting The Deal Through: Insurance Litigation 2018Matheson Law Firm
Sharon Daly, Head of the Commercial Litigation Insurance team and April McClements, Partner in the Insurance and Dispute Resolution team co-author the Ireland chapter for Getting The Deal Through: Insurance Litigation 2018.
Global business attorney Luis Alcalde presented "Managing International Risks + Corporate Investigations" on Thursday, January 16, at the Schneider Downs' Corporate Corruption + Fraud Seminar.
Luis discussed international corporate investigations involving the Foreign Corrupt Practices Act (FCPA), corporate ethics and other regulatory matters.
Guide to The Bribery Act 2010 by Josiah HincksJosiahHincks
The Bribery Act 2010 came in to force in the UK in July 2011.
It creates criminal offences for individuals who give or receive bribes.
It also creates an offence for Companies and Partnerships who fail to prevent bribery occuring. The fines are unlimited.
This slide show from Josiah Hincks Solicitors in Leicester presents everything you need to know about Bribery, The Bribery Act, and how to ensure your business is compliant.
Visit http://www.josiahhincks.co.uk for more information about our firm of solicitors in Leicester.
Julie Murphy O'Connor and Gearoid Carey provide an overview on Enforcement of Foreign Judgments in Ireland in the 2018 edition of Getting the Deal Through.
The Legal 500: Bribery and Corruption Comparative Guide 2018Matheson Law Firm
Claire McLoughlin and Karen Reynolds, Partners in the Commercial Litigation and Dispute Resolution Department and Co-heads of the Regulatory and Investigations Group, co-author the Ireland chapter for The Legal 500: Bribery and Corruption Comparative Guide 2018.
C-Suite Workshop presented by Stephen Booth and Peter Stewart on 10 April 2019LaraMartinsons
C-Suite Workshop: Modern Slavery, Anti-Bribery & Corruption, Privacy and Whistleblowers presented by Stephen Booth and Peter Stewart at Coleman Greig, Parramatta
Getting The Deal Through: Insurance Litigation 2018Matheson Law Firm
Sharon Daly, Head of the Commercial Litigation Insurance team and April McClements, Partner in the Insurance and Dispute Resolution team co-author the Ireland chapter for Getting The Deal Through: Insurance Litigation 2018.
This presentation was delivered at the ISO 37001 & Anti-Bribery PECB Insights Conference by Ralph Haddad, Global Compliance Leader at Anti-Corruption at CAE Inc.
REDTRAY Inspirations Event: Compliance and croissants the bribery act 2010 finalKate Graham
These presentations were delivered at the Inspirations event on 18 January 2011, focused on the new Bribery Act and the implications for UK organisations. Hosted by REDTRAY and Grant Thornton, we were joined by expert guest speakers from both Grant Thornton and Duane Morris.
On Tuesday, 23 September, MCRB hosted a half-day workshop on “Anti-Corruption Programmes” for Myanmar businesses in Yangon. The workshop, held in collaboration with Spectrum – a Yangon-based sustainable development knowledge network - was the first in a series of events to follow-up on the Transparency in Myanmar Enterprises (TiME) report and build business capacity in the area of anti-corruption and human rights.
Key Take aways -
» To successfully develop and implement an anti-corruption framework, an organization must have an excellent tone at the top.
» An anti-corruption framework must have a robust, clear, and comprehensive de nition section for any employee or vendor to refer to.
» Assess your organization’s culture with adequate risk assessments and take steps to mitigate problem areas.
» The degree of con dentiality and mechanism of reporting offered to employees will inform the level of trust those
employees maintain.
» Investigation procedures and disciplinary actions that an employee might face are indicators of an organization’s tolerance and intolerance toward misconduct.
In this age of global business operations and opportunities, it is a business imperative to have an effective FCPA Compliance Program. In this webinar co-hosted with Paul Murdock of MCG Consulting we explore and discuss Foreign Corrupt Practices Act compliance and actions to achieve a FCPA Compliance Program.
For a full video of the recording visit: https://mco.mycomplianceoffice.com/mco-webinar/foreign-corrupt-practices-act-fcpa-compliance-webinar
The Bribery Act 2010 gained Royal Assent on 8 April 2010 and represents the most significant change in the UK government’s approach to tackling bribery and corruption for over 100 years. The Bribery Act 2010 replaces outdated legislation, bringing the UK in line with the OECD AntiBribery Convention and aims to make the UK a better place for conducting business.
The primary focus for companies is the new offence of failure by a commercial organisation to prevent bribery. All offences carry a maximum prison sentence of 10 years, with the exception of the offence relating to failure to prevent bribery, which carries an unlimited fine.
Where a director is convicted of bribery, they may also be disqualified from holding a director position for up to 15 years
The globalised business environment of today necessitates a strong network of global vendors that play a critical role in the business and can help bring considerable opportunities.
10 Ways To Reduce The Risk of Bribery and Corruption.pdfWajidKhanMP
Corruption affects all nations, causing instability, inequality, poverty, and eroding national wealth. But there are ways to minimize the risk to your business. Despite strict anti-corruption laws, corruption remains a significant risk. Wajid khan Mp Shares According to PwC's Global Economic Crime Survey, nearly half of the world's businesses have faced fraud, including bribery and corruption, in the last 24 months.
How to reduce bribery and corruption
Learn ten simple and effective strategies to reduce the risk of bribery and corruption in your company.
1. Updated Anti-Bribery and Anti-Corruption Policy
Most UK companies have an anti-corruption policy, but it depends on how they implement it. Ensure employees understand the company's policies and expectations regarding bribery and corruption. We need to know what is and is not acceptable regarding gifts, entertainment, donations, sponsorships, and political contributions. Regular training on crime should be provided to maintain awareness.
10 Ways To Reduce The Risk of Bribery and Corruption.pdfWajid Khan MP
10 Ways To Reduce The Risk of Bribery and Corruption
Corruption affects all nations, causing instability, inequality, poverty, and eroding national wealth. But there are ways to minimize the risk to your business. Despite strict anti-corruption laws, corruption remains a significant risk. Wajid khan Mp Shares According to PwC's Global Economic Crime Survey, nearly half of the world's businesses have faced fraud, including bribery and corruption, in the last 24 months.
How to reduce bribery and corruption
Learn ten simple and effective strategies to reduce the risk of bribery and corruption in your company.
1. Updated Anti-Bribery and Anti-Corruption Policy
Most UK companies have an anti-corruption policy, but it depends on how they implement it. Ensure employees understand the company's policies and expectations regarding bribery and corruption. We need to know what is and is not acceptable regarding gifts, entertainment, donations, sponsorships, and political contributions. Regular training on crime should be provided to maintain awareness.
Alongside your training, establish a process to help you remember the dos and don'ts, such as B. Checklists and Travel Guidelines. Employees should understand that any gift or entertainment received must have a legitimate business purpose, be appropriate, and be listed on the company's gift and entertainment register. Wajid khan suggests Clarifying what you mean by "justified" and "deserved." Please don't leave it up to interpretation.
2. Sound from directly above
Employee awareness of anti-corruption policies is only half the story. Building an anti-bribery culture requires clear and consistent messaging from the top down.
Boards, business owners, and all members of the compliance function must be clear that bribery and corruption are intolerable and that anyone found guilty faces the most severe penalties.
But most importantly, those at the top live their preaching and believe in the importance of anti-corruption policies. Otherwise, employees will not embrace that culture, and dialogue about anti-bribery training will not be taken seriously.
3. Integrate ABAC principles into corporate culture
See Anti-Bribery (ABAC) in company manuals, reports, and training. By including his ABAC clause in all supplier contracts, he establishes ground rules in advance and sets up appropriate termination clauses in case of suspected violations.
Canadian politician Wajid khan discusses Finally, communicate to employees how important they are to prevent bribery and empower them to do their part in maintaining compliance
When Corporate Governance Fails - A look into decades of bribery by Rolls RoyceOliver Madden
MBA Presentation
MBA in International Management: ESCP Europe Business School
Group Presentation: Ethics & Corporate Social Responsibility
Analysis of Rolls Royce corruption allegations
The Walter Lilly case - some harsh lessons learnt - construction update semin...Blake Morgan
Richard Wade from Blake Morgan talked about The Walter Lilly case and the lessons learnt at Blake Morgan and Rund's Construction update seminar on 5 November 2014 in Southampton.
Blake Lapthorn's London Pensions conference 19 March 2014Blake Morgan
On Wednesday 19 March 2014, Blake Lapthorn's Pensions team hosted its London Pensions conference - 'The State of Pensions'. The team were joined by Ed Tomlinson of SEI and Kevin Wesbroom of Aon Hewitt. Speakers brought delegates up to date with recent and future developments and demonstrated ways in which some of the current and future challenges can be met.
Blake Lapthorn's In-House Lawyer and Decision Makers' forum - 'Health & Safet...Blake Morgan
On Tuesday 25 February 2014, Blake Lapthorn's commercial litigation team hosted an In-House Lawyer and Decision Maker's forum in Southampton. Our speakers, John Mitchell and Nicola Hutchins, discussed the changing landscape of Health & Safety law.
Blake Lapthorn's green breakfast with the Environment BankBlake Morgan
On Wednesday 4 December, Blake Lapthorn's climate change team hosted a green brekfast ith Dr. Tom Tew, Chief Executive of the Environment Bank. Tom talked about the role of bio-diversity off setting.
Blake Lapthorn green breakfast with BRE globalBlake Morgan
On Tuesday 3 December, Blake Lapthorn's climate change team hosted a green breakfast seminar. Guest speaker Chris Cousins of BRE Global, talked about sustainable building for a Green future.
Blake Lapthorn green breakfast with Dr. Barbara Hammond of the Osney Lock Hyd...Blake Morgan
On Wednesday 20 November 2013, Blake Lapthorn's climate change team hosted a green breakfast seminar. Guest Speaker Dr. Barbara Hammond, talked about the high profile and long awaited, first community owned micro hydro scheme on the upper Thames.
Blake Lapthorn green breakfast with The Green Blue - 19 November 2013Blake Morgan
On Wednesday 19 November 2013, Blake Lapthorn's Climate Change team hosted a green breakfast seminar titled 'Influencing change in the UK leisure marine sector', with guest speakers Jane Swan and Dan Reading of The Green Blue.
Blake Lapthorn's green breakfast with guest speaker Keeran Jugdoyal, Faithful...Blake Morgan
On Wednesday 13 November 2013, Blake Lapthorn's climate change team hosted a green breakfast seminar. Guest speaker Keeran Jugdoyal, Mechanical Engineering Manager at Faithful+Gould, talked about the lessons his company has learnt about the end use of sustainable buildings.
Blake Lapthorn green breakfast with URS GlobalBlake Morgan
On Wednesday 6 November 2013, Blake Lapthorn's climate change hosted a green breakfast seminar. Guest Speaker Robert Spencer, Business Line Director - Sustainability at URS Infrastructure & Environment UK Ltd, talked about integrating eco system services and Natural Capital considerations into business planning and strategy.
Blake Lapthorn green breakfast with Seacourt Printing Ltd - 16 October 2013Blake Morgan
On Wednesday 16 October 2013, Blake Lapthorn's Climate Change team hosted a green breakfast seminar. Guest speaker Gareth Dinnage, Managing Director of Seacourt Printing, talked about his companies move from being a standard 'dirty' printer to the first closed loop, Zero Waste, printing company in the world.
Blake Lapthorn green breakfast with Rapanui - 18 September 2013Blake Morgan
On wednesday 18 September 2013 Blake Lapthorn's Climate Change team hosted a green breakfast seminar titled Eco-fashion for the green consumer, with guest speaker Mart Drake-Knight of Rapanui.
Blake Lapthorn's In-House Lawyer and Decision Makers' forumBlake Morgan
Blake Lapthorn's Litigation Dispute Resolution and Employment teams joined up to present a forum on social media and confidentiality on 17 September 2013, at Blake Lapthorn's Oxford office.
Blake Lapthorn Academies conference, Southampton - 18 June 2013Blake Morgan
Blake Lapthorn's Education team hosted a summer conference for Academy schools and those looking to convert to academy status. The conference provided guidance and advice with the guest speaker being Zenna Atkins, former head of Ofsted.
Blake Lapthorn green breakfast with Mike Putnam, Skanska UK - 8 May 2013Blake Morgan
On Wednesday 8 May 2013 Blake Lapthorn's Climate Change team hosted a green breakfast seminar. Guest speaker Mike Putnam, President and CEO of Skanska UK, talked about his companies 'Journey to Deep Green'.
The Indian economy is classified into different sectors to simplify the analysis and understanding of economic activities. For Class 10, it's essential to grasp the sectors of the Indian economy, understand their characteristics, and recognize their importance. This guide will provide detailed notes on the Sectors of the Indian Economy Class 10, using specific long-tail keywords to enhance comprehension.
For more information, visit-www.vavaclasses.com
How to Make a Field invisible in Odoo 17Celine George
It is possible to hide or invisible some fields in odoo. Commonly using “invisible” attribute in the field definition to invisible the fields. This slide will show how to make a field invisible in odoo 17.
The Art Pastor's Guide to Sabbath | Steve ThomasonSteve Thomason
What is the purpose of the Sabbath Law in the Torah. It is interesting to compare how the context of the law shifts from Exodus to Deuteronomy. Who gets to rest, and why?
This is a presentation by Dada Robert in a Your Skill Boost masterclass organised by the Excellence Foundation for South Sudan (EFSS) on Saturday, the 25th and Sunday, the 26th of May 2024.
He discussed the concept of quality improvement, emphasizing its applicability to various aspects of life, including personal, project, and program improvements. He defined quality as doing the right thing at the right time in the right way to achieve the best possible results and discussed the concept of the "gap" between what we know and what we do, and how this gap represents the areas we need to improve. He explained the scientific approach to quality improvement, which involves systematic performance analysis, testing and learning, and implementing change ideas. He also highlighted the importance of client focus and a team approach to quality improvement.
How to Split Bills in the Odoo 17 POS ModuleCeline George
Bills have a main role in point of sale procedure. It will help to track sales, handling payments and giving receipts to customers. Bill splitting also has an important role in POS. For example, If some friends come together for dinner and if they want to divide the bill then it is possible by POS bill splitting. This slide will show how to split bills in odoo 17 POS.
We all have good and bad thoughts from time to time and situation to situation. We are bombarded daily with spiraling thoughts(both negative and positive) creating all-consuming feel , making us difficult to manage with associated suffering. Good thoughts are like our Mob Signal (Positive thought) amidst noise(negative thought) in the atmosphere. Negative thoughts like noise outweigh positive thoughts. These thoughts often create unwanted confusion, trouble, stress and frustration in our mind as well as chaos in our physical world. Negative thoughts are also known as “distorted thinking”.
The Roman Empire A Historical Colossus.pdfkaushalkr1407
The Roman Empire, a vast and enduring power, stands as one of history's most remarkable civilizations, leaving an indelible imprint on the world. It emerged from the Roman Republic, transitioning into an imperial powerhouse under the leadership of Augustus Caesar in 27 BCE. This transformation marked the beginning of an era defined by unprecedented territorial expansion, architectural marvels, and profound cultural influence.
The empire's roots lie in the city of Rome, founded, according to legend, by Romulus in 753 BCE. Over centuries, Rome evolved from a small settlement to a formidable republic, characterized by a complex political system with elected officials and checks on power. However, internal strife, class conflicts, and military ambitions paved the way for the end of the Republic. Julius Caesar’s dictatorship and subsequent assassination in 44 BCE created a power vacuum, leading to a civil war. Octavian, later Augustus, emerged victorious, heralding the Roman Empire’s birth.
Under Augustus, the empire experienced the Pax Romana, a 200-year period of relative peace and stability. Augustus reformed the military, established efficient administrative systems, and initiated grand construction projects. The empire's borders expanded, encompassing territories from Britain to Egypt and from Spain to the Euphrates. Roman legions, renowned for their discipline and engineering prowess, secured and maintained these vast territories, building roads, fortifications, and cities that facilitated control and integration.
The Roman Empire’s society was hierarchical, with a rigid class system. At the top were the patricians, wealthy elites who held significant political power. Below them were the plebeians, free citizens with limited political influence, and the vast numbers of slaves who formed the backbone of the economy. The family unit was central, governed by the paterfamilias, the male head who held absolute authority.
Culturally, the Romans were eclectic, absorbing and adapting elements from the civilizations they encountered, particularly the Greeks. Roman art, literature, and philosophy reflected this synthesis, creating a rich cultural tapestry. Latin, the Roman language, became the lingua franca of the Western world, influencing numerous modern languages.
Roman architecture and engineering achievements were monumental. They perfected the arch, vault, and dome, constructing enduring structures like the Colosseum, Pantheon, and aqueducts. These engineering marvels not only showcased Roman ingenuity but also served practical purposes, from public entertainment to water supply.
Welcome to TechSoup New Member Orientation and Q&A (May 2024).pdfTechSoup
In this webinar you will learn how your organization can access TechSoup's wide variety of product discount and donation programs. From hardware to software, we'll give you a tour of the tools available to help your nonprofit with productivity, collaboration, financial management, donor tracking, security, and more.
Blake lapthorn Bribery Act Thames Valley HR forum - 13 september 2011
1. Thames Valley HR forum
Bribery Act 2010
Nicola Diggle
Blake Lapthorn
2. How Corrupt is UK PLC?
Transparency International Corruption Perception
Index
180 Countries Ranked – low score is good
UK ranked 11th 2005 (better)
UK ranked 20th 2010 (worse)
3. What does the Bribery Act cover?
Prevents the giving or receiving of a financial or other
advantage to encourage or reward the improper
performance of functions or activities
The Act prohibits:
– Bribing
– Being bribed
– Bribing a foreign public official; and
– The "commercial organisation offence" of failure to
prevent bribery
In force with effect from 1 July 2011
4. Penalties for breach of the Act
Individuals face up to ten years' imprisonment
Commercial organisations (including partnerships)
risk:
– an unlimited fine
– ban on tendering for public contracts
– directors, managers and company secretaries can also
face individual liability (for consent or connivance)
5. Main Features of the Bribery Act 2010
General Offences - Bribing or Receiving a Bribe
Paying or offering to pay a bribe
Requesting or receiving a bribe
6. Main Features of the Bribery Act 2010
Examples
Bribing a planning officer to grant you planning
permission
Planning officer asking you for a reward for granting
permission
Sometimes making the offer itself is enough
Corporate hospitality is ok provided it is reasonable
and proportionate
7. Main Features of the Bribery Act 2010
Bribing of Foreign Public Officials (FPO)
Cannot bribe overseas officials
Local written laws that permit investment in the local
economy or paying for training is acceptable
Facilitation payments are prohibited unless permitted
by local law
SFO will prosecute if payments are routinely made
8. Main Features of the Bribery Act 2010
Territorial Jurisdiction
Rules relating to the two general offences and bribing
a Foreign Public Official
Offence committed if any act or omission takes place
in the UK
Offence committed if the person has a “close
connection” with the UK
Defined as a UK citizen, resident, company or
Scottish Partnership
9. Main Features of the Bribery Act 2010
Corporate Offence of Failing to Prevent Bribery
A relevant commercial organisation (C) is guilty of an
offence if a person (A) associated with C bribes
another person intending to obtain or retain:
business for C
an advantage in the conduct of business for C
Relevant commercial organisation :
UK company or partnership doing business here or
elsewhere
Overseas company/partnership carrying on business
or part of business here
10. Main Features of the Bribery Act 2010
Corporate Offence of Failing to Prevent Bribery
A relevant commercial organisation (C) is guilty of an
offence if a person (A) associated with C bribes
another person….
A person is associated with C (disregarding any
bribe under consideration) if A performs services
for or on behalf of C
Can be an agent, subsidiary or parent company but
will depend on all the relevant circumstances
An employee of C is presumed to be providing
services for C
11. Main Features of the Bribery Act 2010
Corporate Offence – Adequate Procedures Defence
C has a defence that it had in place adequate
procedures designed to prevent persons associated
with C from undertaking such conduct
Adequate procedures not defined in the Act but
Guidance now published to assist companies
Objective is to support businesses in determining the
sorts of bribery measures they can put in place
CBI has lobbied hard to get better clarification from
Government on the Act
12. Main Features of the Bribery Act 2010
Guidance on Adequate Procedures
Six principles which underpin Bribery Prevention:
Risk Assessment is first then
Top Level Commitment )
Due Diligence )
Proportionate Procedures ) Risk Mitigation
Communication and training )
Monitoring and Review )
13. Six principles
First – Undertake a Risk Assessment
You must regularly and comprehensively assess the
nature and extent of risks relating to bribery which
you are exposed
No “one size fits all”
Skills of persons performing risk assessment
Internal risks - unawareness of staff of risks
External risks – Country, Transaction, Partner, Sector
14. Six principles
Top Level Commitment
The Board of Directors are committed to preventing
bribery
Publish statements of commitment to counter bribery
for internal and external communication
Appoint a senior person to oversee implementation of
anti bribery programme
15. Six principles
Due Diligence
You have due diligence policies and procedures in
place which cover:
– all parties to a business relationship
– agents and intermediaries
– all forms of joint ventures
– all markets in which you operate
16. Six principles
Proportionate Procedures
Procedures and therefore resources expended need
to be proportionate to risks you face
Procedures should ensure that there is a practical
and realistic means of achieving your anti-bribery
policy
17. Six Principles
Communication and Training
Anti-bribery policies and procedures are embedded
and understood throughout the organisation
Appoint someone senior to oversee the
implementation
– Internal and external communication
– Method and timescale of training
Various methods of training
Arrangements for Monitoring
Penalties for breaching policy
18. Six principles
Monitoring and Review
Monitoring and review mechanisms to ensure
compliance
Internal monitoring
Transparency is important
External auditors
19. Miscellaneous Matters
The Likelihood of a Prosecution
– Resources
– Evidential Test
– Public Interest Test
– Must have regard to Guidance
Sentence
– 10 years imprisonment for an individual convicted of an
offence (nb senior officer liability where corporate
offence committed)
– Unlimited fine for company
20. What should organisations be doing about the Act?
– Anti-bribery/ethical conduct policy with zero tolerance
– Any breach of policy deemed gross misconduct
– Gifts/hospitality policy - reasonable and proportionate
– Check political and charitable donations
– No policies which reward excessive risk
– No incentives for employee to commit bribery offence
– Vetting policy/additional recruitment checks
– No discrimination against nationals of other countries
21. What should organisations be doing about the Act?
Consider amending:
– Contracts of employment
– Director service agreements
– Non-employee contracts
– Disciplinary policy
– Whistleblowing policy
– Expenses policy
– Bonus/commission schemes