Bribery Act 2010

Do you have a compliance policy for this Act as the Serious Fraud Office have commented they are going to be more aggressive in pursuing breaches and taking action – recent cases and the levels of fines (for example in a recent case concerning Sweett Group in relation to a hotel construction contract in Abu Dhabi they were fined £2.5m) already shows that the enforcement of this Act is ramping up. Fines can be unlimited and custodial sentences up to ten years – and remember these can fall on individual directors and officers as well as the company.

Simply having a policy in place is not sufficient as you must also undertake training and carry out internal monitoring of your processes and procedures. Ignorance is no defence and turning a blind eye will, not surprisingly, be much more culpable. Enforcement is equally directed at large and smaller companies.

For further advice and assistance on reviewing any policies please contact Daljit Singh.