Bribery & Corruption

The last two years have seen a steep rise in the successful enforcement of the UK Bribery Act 2010 against individuals and companies involved in corrupt practices by the Serious Fraud Office (SFO) and the City of London Police Overseas Corruption Unit. This trend will continue and is a warning to businesses that the UK authorities are serious about confronting domestic and international corruption.

The Bribery Act 2010, which came into force on 1 July 2011, makes it a criminal offence to give, promise or offer a bribe or to request, agree to receive or accept a bribe either in the UK or abroad, with an offence specifically relating to foreign public officials. The Act also makes it a offence for a company to fail to prevent bribery within its organisation. In order to avoid a conviction, a company will have to demonstrate that it had implemented “adequate procedures” to prevent the commission of bribery or corruption by or on its behalf.

Companies must implement and review their anti-corruption policies to ensure that they are robust and that their procedures are effective in detecting acts of bribery by its employees, subsidiaries, agents, and other connected persons. Failure to do so may result in punishing fines, and possibly imprisonment.

On 26 February 2016 Sweett Group plc, a London-based global building and infrastructure company, was ordered by a UK court to pay £2.25 million (including a fine of £1.4 million) for violating Section 7 of the UK Bribery Act of 2010. This was the first ever conviction and sentence for a company under Section 7, which in essence penalizes companies for failing to prevent bribes made on their behalf. The conduct at issue related to a three-year arrangement in the UAE to secure contracts related to large building contracts.

We can support your company on compliance by providing hands on advice including auditing, preparation and implementation of internal policies, procedures and training. In particular, the ISO 37001 for Anti-Bribery Management Systems. We can help carry out internal investigations into potential corrupt activity within an organisation and self-reporting. We provide assistance and representation if you or your company faces a criminal investigation and prosecution.


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