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The UK has one of the toughest anti-bribery and corruption regimes in the world. The corporate criminal offence of failing to prevent bribery can be committed by businesses (large and small), charities and public authorities anywhere in the world, and regardless of whether or not they are aware of bribery taking place.
With consequences including unlimited fines for organisations, debarment from tenders, irreparable damage to reputation and prison sentences of up to 10 years for individuals, compliance with the law is essential.
Our expert team has extensive experience of advising clients on developing and implementing tailored compliance programmes that are appropriate to their needs. Our focus is on providing practical and pragmatic advice that meets the needs of each client and fits with its existing culture and practices as well as the actual risks it faces.
Clients - advising national and international business, charities and public bodies on developing and implementing anti-bribery and corruption compliance programmes.
Sectors – knowledge of the key risks faced by different sectors including retail, luxury goods, construction, charities, insurance and health.
Risk assessment - carrying out detailed risk assessments in order to develop compliance policies and procedures in line with MoJ guidance on 'adequate procedures' including the provision of comprehensive risk assessment questionnaires and coordinating brainstorming sessions and interviews.
Policies and procedures – developing and implementing policies and procedures that reflect the risk profile of the organisation including briefing senior managers and ensuring the compliance controls and monitoring are supported from the top.
Training – developing and providing bespoke interactive training for employees at all levels of an organisation.
Corporate - advising on bribery and corruption issues associated with corporate sales and acquisitions including multi-jurisdictional due diligence and in-depth risk assessment.
Our discussion starts with Kweku Adoboli recounting his experiences during the 2011 UBS Swiss bank scandal, and moves to the various lessons learned and the potential solutions for minimising the risk of wrongdoing.
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On 21 February 2018 Skansen Interior Limited (SIL) was found guilty of the offence under section 7 of the UK Bribery Act 2010 (the Act) of a failure to prevent bribery.
Update in the light of experience following the County Court judgment in Martin Retail Group Limited v Crawley Borough Council (Martins case).
Clients comment that 'he is incredibly knowledgeable about the law and so pragmatic in his advice.'
Speaking alongside the UK Ministry of Justice at an anti-corruption and anti-bribery seminar organised by the UK Foreign and Commonwealth Office in Johannesburg, South Africa.
Advising a multi-national on carrying out anti-bribery due diligence in relation to a corporate sale. This included reviewing the adequacy of existing policies and procedures, coordinating in-depth country by country risk assessments and questionnaires and advising on identified risks.
Advising a national charity on carrying out a risk assessment and putting in place anti-bribery policies and procedures in line with the MoJ’s guidance on 'adequate procedures'”. This involved a detailed review of the risks faced by the charity across all aspects of its activities including corporate fundraising and procurement activities.
Providing tailored and interactive training for clients across multiple jurisdictions and sectors including the use of webinars. We provide training ranging from 30 minute briefings for all employees to in-depth role-specific training for small groups of senior managers.
Plans for new offences of failing to prevent money-laundering and fraud continue to progress. The plans, originally announced by David Cameron in May 2016, would complement a similar offence.
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