Although currently subject to delay it seems sure that sooner or later the Bribery Act will come into force. It will make it a criminal offence for someone to offer, ask for, or accept, an “inducement” that may be a reward for acting improperly. Organisations will be committing an offence if they fail to prevent bribery by someone associated with them.
Consider the following scenarios:
- A supplier recently bought them lunch.
- A customer is organising a 3 day conference in a 5 star hotel, all expenses paid and the “conference” time is minimal.
- An employee of a major customer has asked them to arrange a large cash payment into an overseas bank account in her name to guarantee the company is shortlisted for a huge contract.
Which of these might be caught by the Act? You might believe that number 1, having coffee or lunch with clients/suppliers is part of everyday business life where as you’d instantly find number 3 very worrying. In the middle, your reaction probably also depends on the sort of organisation and sector you work in – what’s generally acceptable or not.
So, how seriously do you need to take the UK Bribery Act? If you’re part of the senior team of any sort of organisation, you should at least check how this may affect your business.
UK Bribery Act – top tips on how to prepare
- Assess the risk – identify the business activities where the Act might be relevant.
- Check there’s a business ethics policy that makes clear what is / isn’t acceptable in terms of giving and receiving gifts and favours of any kind.
- Check that employees / suppliers / customers / service users know about your policy? Check it’s communicated clearly in staff handbooks, possibly included in contracts or service level agreements, and covered in induction or training.
- Check whether your disciplinary procedure or other policies / procedures need changing.
- Check that the policy identifies someone senior whom someone can speak to confidentially if they believe an offence has taken place.
We shall have to wait to see how the Act is interpreted in practice and what effect it has, but meanwhile, you can make sure your organisation is prepared.
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