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��o2x���A��i���ALB Under the new Bribery Act individuals could face up to 10 years in prison and companies could receive unlimited fines. t/�fl*^,�&aj;��J �d�!�53IB�P�(G����5��mfR���|eF�[�R�Q�����T��n����Ի�ɻ��f�ۗ�.�r�����b �@K�x�T����Ҹ�$
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The Bribery Act 2010 was introduced to update and enhance UK law on bribery including foreign bribery in order to address better the requirements of the 1997 OECD anti-bribery Convention. endstream
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The guidance has been kindly supported by FTI Consulting and DLA Piper. {���� �ŋ��_���&�ME+&%����}^�>�r��?o�VE�E�}H��T�1��q����g8��\fC�ŗ>���j6�������"s��>�
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k��PUvm�/�8��Ϳ�.K���s��բ��0��˖�Z�i�@� This policy also applies to all third parties who act on behalf of the UK Club. For more information, visit The UK Bribery Act: Adequate Procedures but Inadequate Guidance? For each area of practice, we provide a summary, best practice tips, full guidance, and links to further resources.
Anti-Bribery Compliance Policy & Guidance Manual filed on November 16th, 2017 Executive Summary • The Bribery Act 2010applies to all partnerships and incorporated organisations (by whatever means), provided they are engaged in commercial activities, irrespective of the purpose for which profits are made.
Illumination with regards the latter area, however, has mostly been found in the Ministry of Justice’s 2011 guidance (the MOJ Guidance) regarding such procedures as well as the limited information that can be gleaned from the handful of prosecutions and DPAs under the Act and occasional public comments from people including Lisa Osofsky (the current Director of the SFO) and Sara Lawson QC (the SFO’s General Counsel).Some additional guidance in the area of what an “adequate” compliance programme may look like became available on 17 January 2020 in the form of a somewhat unheralded update to the SFO’s Operational Handbook (the Handbook) entitled The Guidance notes that prosecutors will need to assess the efficacy of a compliance programme for different periods – depending on the decision being considered, the past, present or future state of the compliance programme may be relevant:The Guidance certainly sheds light on the importance of the assessment of a compliance programme, the different decisions that such assessment impacts and how an assessment can be carried out – early on in an investigation and with information obtained from a variety of sources. �>~Ø�1�c�8��-�9|n��EŖ��Tf�M�˔�L_�܌Y�?�\�{v��#%�}�4G�;Պ�KP9�IĤ��)��P� q�d�bu��%j�*aD=yX� �r;\��� �`D�) Since the UK Bribery Act (the Act) came into force on 1 July 2011, companies have grappled with a number of key questions arising under the Act. 1176 0 obj
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Steptoe has more than 500 lawyers and other professional staff across offices in Beijing, Brussels, Chicago, Hong Kong, London, Los Angeles, New York, San Francisco, and Washington. The Bribery Act reforms the criminal law to provide a new, modern and comprehensive scheme of bribery offences that will enable courts and prosecutors to respond more effectively to bribery at home or abroad. {M컐��h��m�q�t(� %%EOF
���X,���X�7GV�4!K��t&)�/�`]�,w5� Notably, it introduces a new strict liability offence for companies and partnerships of failing to prevent bribery.For includes our original Adequate Procedures Guidance to the UK Bribery Act; a leading resource for compliance and legal professionals, which has been downloaded over 45,000 times from TI-UK’s website. These questions have included the extent of cooperation required from a corporation to benefit from any credit from the Serious Fraud Office (SFO) and also the basis on which a company’s compliance programme might be deemed adequate in order that the company can avail itself of the “adequate procedures” defence to any charge under section 7 of the Act.Compliance officers and in-house counsel received further guidance in the first of these areas – i.e., what steps must be taken in order to receive credit from the SFO for doing so – in summer 2019 when the SFO published its Corporate Co-Operation guidance. endstream
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Bribery Act 2010 (UK): A Compliance Guide .