Honesty is Always the Best Policy – The 2010 Bribery Act

Nov 25, 2016 | TC blog

2010 Bribery Act

Most people are familiar with the rules regarding money laundering, which apply to businesses in a number of sectors. In our experience, however, people are less aware of an associated set of rules which are connected with the 2010 Bribery Act.

The Act covers situations where your staff might be induced or coerced into doing something which is fraudulent, illegal or unethical in return for an incentive. While this could include money laundering or tax evasion, it actually extends far beyond.

Making sure your staff are aware of the provisions of the Act and giving them the tools to recognise situations where the acceptance of a gift or incentive would be deemed unusual or excessive is essential. This includes having a clear reporting procedure and an assurance that any report made in good faith will be fully supported by the company.

Of course, genuine hospitality or small gifts such as promotional items, don’t fall foul of the regulations, as long as it is reasonable and proportionate. The context and nature of the business relationship is clearly critical in determining this.

According to government guidance, these are the six key principles business should observe.

  • Proportionate Procedures. These need to be appropriate “to the nature, scale and complexity of the commercial organisation’s activities.”
  • Top-level Commitment. The management of your organisation needs to foster a culture in which bribery is never acceptable.
  • Risk Assessment. Commercial organisations must assess the nature and extent of their exposure to potential external and internal risks of bribery.
  • Due Diligence. You must take “a proportionate and risk based approach” in respect of persons who perform or will perform services for, or on behalf of, the organisation.
  • Communication (including training). Your bribery prevention policies and procedures need to be embedded throughout your organisation.
  • Monitoring and Review. It is essential to review your policies and make improvements where appropriate.

We would recommend that businesses write a robust Anti-Bribery and Corruption Policy, which is reviewed annually. We would also recommend that this policy provides the foundation of staff training, which could perhaps be part of your employee induction process.

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