Hospitality packages at the Olympics will start to go on sale soon and it is expected that there will be a great interest in
purchasing such packages. Despite the delay to implementation of the Act, some companies may have already put in place strict guidelines prohibiting their staff from accepting any form of corporate hospitality or limiting any entertainment to marginal gifts or activities.
Partner Jane Player has noted that the price of some packages is very high. As a result she thinks it possible that a number of invitees may be forced to reject an offer of entertainment due to corporate concerns about the scope of the Act and/or recently implemented strict corporate hospitality policies. This raises the chance that the money spent could be wasted.
There has been a great deal of lobbying from the sports and hospitality industry sector as it is said that the Bribery Act constraints on entertainment and hospitality may well mean the end of these industry sectors and also limit vital corporate sponsorship of sports teams. This lobbying has been taken seriously by the government and the fact that the Bribery Act has been delayed to enable the government to provide Guidance on this matter demonstrates this. Whilst the Lord Chancellor has recently indicated that companies will be able to continue with their normal corporate hospitality policies, it is not clear whether the price of Olympic packages will cause them to fall outside of such assurances. What might be of assistance in this regard is the SFO's guidance on corporate hospitality that is due to be published - independently of the Guidance - on or around the same time as the Guidance is released.
If you are unsure how the Bribery Act may impact on your strategy budgeting and your marketing planning, please do not hesitate to contact a member of our team. What is clear is that companies should not be shunning corporate hospitality and the commercial opportunities it offers without having given the issues and potential risks consideration.
We also continue to stress the importance of starting to implement the necessary corporate policies. This implementation may be a time-consuming process and it should not be delayed unnecessarily.