Anti-bribery
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, regardless of whether or not they’re 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.
What we do
- Clients - advising national and international companies, 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.
Featured experience
Multi-national: due diligence for a corporate sale
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.
A national charity: risk assessment and anti-bribery policies and procedures
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.
Training for clients
Providing tailored and interactive training for clients across multiple jurisdictions and sectors including the use of webinars. Training provided ranges from 30-minute briefings for all employees to in-depth role-specific training for small groups of senior managers.
Key contacts
Matthew Woodford
Partner
You may be interested in...
Legal Update - Food and drink regulatory update
Food for Thought: Food and drink regulatory update - Autumn 2023
Legal Update
Economic Crime and Corporate Transparency Act 2023 – what does it mean for my company?
Legal Update
King’s Speech gives the green light for autonomous vehicles
Opinion
What’s lurking in your garden? The UK’s most dangerous and invasive plants
Opinion
Landowner fined £15,000 after public attacked by cows
Legal Update
The future of autonomous technology - August 2023
Legal Update
Polluters to face unlimited penalties under new legislation
Legal Update
Browne Jacobson grows Cardiff team with two new appointments
Legal Update
Higher-risk buildings – are you ready for 30 September 2023?
Legal Update
Government to expand network and information systems regulations
Opinion
New provisions for higher-risk residential buildings now in force
Legal Update
UK Government publishes the Online Safety Bill: an overview
Legal Update
Update on the Digital Services Act (“DSA”) – Important Dates and Deadlines Looming
Legal Update - Public matters newsletter
Public matters - January 2023
Press Release
Browne Jacobson advises Natural England on investigation of ‘first in its kind’ sentenced Devon farmer
Legal Update
Biodiversity Net Gain: positive for nature and an opportunity for landowners
Opinion
Logistics firm fined for multiple failings leading to asbestos exposure
Logistics company Eddie Stobart has been fined £133,000, after a series of failures which took place whilst excavation work was carried out, exposing its staff to asbestos.
Published Article
Consumer duty part 2 - 'The drill-down' into the 'cross-cutting' rules
Opinion
Directors fined for unsafe removal of asbestos
Two directors of a construction company were fined after failing to ensure the safe removal of asbestos from a plot of land. On 14 and 15 November 2021, Directors Anthony Sumner and Neil Brown, of Waterbarn Limited were involved in the uncontrolled removal of asbestos material from a plot of land in Grasscroft, Oldham.
Opinion
Don't look down
An engineering company in Tyne and Wear was fined £20,000 after a worker fractured his pelvis and suffered internal injuries after falling through a petrol station forecourt canopy, whilst he was replacing the guttering.
Legal Update
DSA approved: Targeted Advertising Rules explained
Opinion
HSE inspection of asbestos in schools
The Health and Safety Executive (HSE) have announced they will be carrying out a programme of inspections to primary and secondary school establishments from September 2022. The inspections will assess how schools are managing the risks from asbestos and meeting the Duty to Manage requirements, set out in Regulation 4 of the Control of Asbestos Regulations 2012.
Opinion
“Red tape” reform and no-fault dismissals
The Government has announced a change to the categorisation of “small” businesses to reduce the amount of regulatory compliance (or “red tape”) required. Currently, SMEs (those with fewer than 250 employees) are exempt from certain regulations – such as the obligation to comply with gender pay reporting. With effect from 3 October, these exemptions will be widened to apply to businesses with fewer than 500 employees.
Legal Update
U-turn on DEI regulatory reporting
Legal Update
Avoiding the pitfalls of WhatsApp
The use of social media platforms and applications can have overwhelmingly positive benefits for public bodies. However, regulatory action recently taken by the Information Commissioner, has highlighted various pitfalls that public bodies should seek to avoid if allowing staff to use social media as a communication tool.
Opinion
Is it hot in here, or is it just me?
Whilst the weather conditions are predicted to be cooling down this week, the Health and Safety Executive (HSE) is asking employers and businesses to consider adapting to recurrent warmer weather conditions for the safety and benefit of their staff. It asks employers to ensure that extreme heat becomes a firm part of longer term risk management. Climate change in any event is something all businesses will need to consider as the warmer weather becomes more frequent - extreme heat is something that will impact employers on a day to day basis.
Legal Update - Shared Insights
Shared Insights: The Fitness to Practise Regime
In this session, our speakers discussed the Fitness to Practise Regime and how we can help.
Published Article - Building Safety Act
The Building Safety Act 2022: Navigating building liability orders
Opinion
Compliance - small businesses and new regulation
The Federation of Small Businesses (FSB) has released a report setting out the impact of new and changing regulations arising from the pandemic on small businesses across the UK.
Legal Update
Construction: Gold Standard Framework – seven months on
We have created a summary of the recommendations and consistent themes which we are now starting to see becoming more embedded in public sector procurement practices.
On-Demand - Building Safety Act
Building Safety Bill – what’s coming and how will it affect you?
Opinion - Building Safety Act
Building Safety Bill receives Royal Assent
Legal Update
Don’t let the lights go out – dealing with an insolvent energy supplier
There are a number of factors which have contributed to the crisis including the huge increase in wholesale natural gas prices, which have risen some 250% since the start of 2021. Since the start of last year, over 30 energy firms have gone bust in the UK alone.
Legal Update
Fraud – why it pays to be vigilant
Financial crime is an increasing threat to all organisations. The modes of facilitating fraud have become easier. Being a victim of fraud as an organisation risks significant financial consequences, but also serious reputational harm and loss of stakeholder confidence.
Opinion - Building Safety Act
Building Safety Bill amendments
Opinion
Draft Bill published to establish a Register of Overseas Entities
The Government has this week published the Economic Crime (Transparency and Enforcement) Bill as part of its measures to crack down on foreign criminals using property in this country to launder money. The Bill proposes the establishment of a Register of Overseas Entities to be maintained by Companies House.
Opinion
HSE Campaign Targets Construction Industry in Birmingham
The HSE has announced a campaign targeting health and safety in the construction industry in Birmingham. The Campaign is in response to a significant increase in development across the city, partly as a result of preparations for the 2022 Commonwealth Games.
On-Demand
COPs 26 and 27: Reflecting Back and Looking Forward – What environmental developments and commitments can we expect in 2022 and beyond?
Watch our webinar on-demand. Issues discussed: summary of the COP26 outputs, predictions for further commitments at COP27, and more.
Opinion
Care home worker fairly dismissed for refusing Covid-19 vaccination
The Tribunal considered whether a care home worker was unfairly dismissed following her refusal to be vaccinated against Covid-19. It is important to note the Claimant’s dismissal pre-dated the compulsory vaccination regulations in force from November 2021.
Published Article
Construction needs to do more to reduce carbon emissions
More needs to be made of these procurement routes, with clients honouring the original concept rather than watering down concepts.