Richard Alderman, director of SFO, spoke on the role of private equity and the implications of the Bribery Act. He looked at the degree of control necessary in an investee company to make that company an “associate” for the purposes of the Act. He moved on to talk about how firms could work with SFO if they discovered corruption in a company they had acquired. Finally, he spoke about hospitality, facilitation payments and incentive payments. He said the latter are not necessarily bribes, if they are commercial and transparent. (Source: SFO Speech on Private Equity and the Bribery Act)