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Will you be accepting bribes this Christmas?


It’s that time of year again. Good food, apocalyptic weather, spending time with the family and finally getting the tablet you’ve been dreaming about. But it can also be a risky time for many organisations. Putting the office party compliance ‘nightmare before Christmas’ to one side, there also is the issue of bribery.

Corporate corruption and malpractice has never been so high up the political agenda, and the Bribery Act 2010 enforces strict distinctions between acceptable Christmas gifts and illegal bribes. 2012 is a very different place compared to two years ago, as SFO guidelines that softened the Act have been withdrawn. So to jog your memory, here’s a short guide to the Bribery Act 2010:

- It’s tough. In fact, it’s been described as ‘the toughest anti-corruption legislation in the world’. As a result, it’s easier to breach than previous legislation. For example, ignorance or the lack of corrupt intent is no excuse.

- The results of such breaches impact individuals. Alongside reputational damage and fines for the organisation, this means criminal prosecution and jail sentences for individuals at all levels of the corporate hierarchy.

- If your organisation is found to have breached the Act, a full defence can only be launched as long as you can show that you had ‘adequate procedures’ in place to prevent bribery. So what does this mean?

What counts as ‘adequate procedures’ varies. Of course, large organisations and those that operate overseas face a bigger risk of bribery than a small company or one that only operates within the UK. As such, your bribery prevention measures and due diligence need to be more thorough.

Your commitment to preventing bribery needs to be demonstrated from the top, with senior leaders ensuring that everyone understands you don’t tolerate bribery. This is a serious responsibility and it’s much easier to slip up than you may think. Don’t just assume it goes without saying.

Effective training is a key part of the ‘adequate procedures’ you need to undertake. So what does it need to cover? We’ve pulled out some key points from the Bribery Act guidance, hefty 45-page document published by the government back in 2010 (emphasis included in original):

- ‘Training provides the knowledge and skills needed to employ the organisation’s procedures and deal with any bribery related problems or issues that may arise.’

- ‘General training could be mandatory for new employees […] but it should also be tailored to the specific risks associated with specific posts.’

- ‘Training ought to achieve its objective of ensuring that those participating in it develop a firm understanding of what the relevant policies and procedures mean in practice for them.’

Based on the guidelines, our advice is that if you have Anti-Bribery and Corruption training in place, it should do more than tick the boxes by making employees wade through page after page of legalese. Will that actually prevent your employees giving or taking bribes? We recommend:

- Focusing on the practical application of the Act. What situations should employees be aware of as potentially risky? What action should they take if they find themselves in such a situation?

- Providing an element of role-based tailoring. All staff need a basic level of training, but some of your staff, for example those in procurement, will be higher risk where bribery is concerned.

- Including both corporate and individual perspectives. You’ve got to go beyond talking about reputational damage. For example, illustrate how that can translate to a decline in business, which in turn can lead to cutbacks in salaries or even in staff.

In the spirit of the season, we’ve slashed the price of our Bribery Act 2010 course, which can be customised to your organisation. Click here if you’d like to demo the course and find out more.

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Saffron Interactive

The Team

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