As you will be aware, the Bribery Act 2010 is coming into force on 1 July 2011.  The Act will strengthen the existing anti-bribery law in the UK, and introduces a number of new offences and penalties, including unlimited fines and imprisonment.  The implications of the Act's provisions are far-reaching, and will impose certain obligations on businesses.  One such obligation is that organisations will need to be in a position to show that they have "adequate procedures" in place to prevent bribery by associated persons. Following from our seminars on the Act in Edinburgh and London, S+W is well placed to assist organisations to comply with its provisions. Our risk compliance team has vast experience in assisting organisations in complying with a wide range of legal obligations and in dealing with regulatory investigations.  We can provide a range of services that can be tailored to your particular needs and risk profile in a cost effective and proportionate way.  These can include:

  • training and awareness raising
  • audit and prevention
  • institutional organisation
  • dealing with investigations

As part of our services, we have produced a package of pro-forma documents for your organisation to use to ensure "adequate procedures" are in place.  This package includes :

  • Outline Paper on Scope and Effect of Bribery Act 2010
  • Anti-Bribery and Corruption Risk Assessment Questionnaire
  • Business Ethics, Anti-Bribery and Corruption Policy
  • Individual Declaration of Compliance with Business Ethics, Anti-Bribery and Corruption Policy
  • Anti-Corruption Management Framework
  • Anti-Corruption Implementation and Training Framework
  • Internal Training Workshop Scenarios
  • Anti-Corruption Due Diligence Questionnaire
  • Anti-Corruption Contractual Provisions and Warranties
  • Whistleblowing Policy
  • Indicative Red Flags: Bribery Act 2010
  • Bribery Act 2010 Compliance – Internal Due Diligence Checklist
  • Bribery Act 2010 Compliance – External Due Diligence Questionnaire
  • Anti-Corruption Statement
  • Completion and Monitoring Checklist
  • Employment Clauses
  • Email Disclaimer Statement
  • Third Party Side Letters amending Service Contracts

a) General version

b) Formal version

  • Suggested Questions and Answers for Employees