On 8 July 2016 the SFO announced that a second DPA had been approved for a UK SME, that cannot be named due to ongoing, related legal proceedings. The suspended charges allege that the company systematically offered bribes to secure contracts overseas between 2004 and 2012. The bribes came to light following the institution of an internal compliance programme 2011. The SME acted on its concerns and instructed a law firm to investigate the matter. Their findings were presented to the SFO who then conducted their own investigation. The SFO found that 28 of the 74 contracts examined were secured as a result of a bribe.

The company is to pay financial orders of £6,553,085, comprised of a £6,201,085 disgorgement of gross profits and a £352,000 financial penalty. The SME has also agreed to cooperate fully with the SFO and to report annually on the effectiveness of its anti-bribery and corruption controls, policies and procedures.

Lord Justice Leveson, in passing judgment stated: “[This conclusion] provides an example of the value of self-report and co-operation along with the introduction of appropriate compliance mechanisms, all of which can only improve corporate attitudes to bribery and corruption.” The SFO Director also noted that the company had demonstrated “exemplary co-operation”, signalling its importance to the agency.