Sam discusses the importance of top level commitment and how it is crucial to developing and maintaining the ethical integrity of any business. This is especially critical with the enactment of The UK Bribery Act since senior board members will be held liable and fully accountable for the actions of their employees and third parties under the ‘failure to prevent bribery’ clause.
The UK Bribery Act will see senior board members held liable and fully accountable for the actions of their employees and third parties under the new corporate offence of ‘failure to prevent bribery’. Sam Eastwood, Norton Rose, discusses the impact of the UK Bribery Act and how it will influence the varied Gifts, Hospitality and Entertainment culture across industries worldwide.
Under the UK Bribery Act, a business is responsible for actions taken not only by employees but also by all 'associated parties'. Third party relationships must be properly managed to comply. Paul Rew covers key questions a business should ask regarding their third party relationships and what third party due diligence really entails.
Facilitation payments are illegal under the UK Bribery Act but permissible in certain circumstances under the FCPA. Sam Eastwood, Norton Rose, discusses these differences and suggests practical steps businesses can take towards a zero tolerance stance.
Under the UK Bribery Act, Adequate Procedures will only be sufficient defense against the new corporate crime of failing to prevent bribery if they are aligned with the specific risks impacting your business. Paula discusses the vital role a risk assessment plays in defining your anti-bribery anti-corruption program and gives some practical advice on key considerations for doing it effectively.