UK Bribery Act

What is it?

  • The UK Bribery Act is modeled on the FCPA, but it is broader, and prohibits bribery of private officials and government officials
  • Bribery is defined as giving a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.
  • Unlike the FCPA, there are no exceptions for grease/facilitating payments

Why You Care

  • The UK Bribery Act subjects companies with any presence in the UK to liability for wrongdoing anywhere in the world, regardless of whether there is a connection between the act of bribery and the UK
  • Organizations can be held liable for the actions of third parties
  • Liability is potentially significant, with unlimited maximum fines and up to 10 years prison for offending individuals
  • Like the FCPA, an effective compliance program (or a program with “adequate procedures”, in the language of the UK Bribery Act), is essential.  With more anti-corruption policies proliferating worldwide, the time to act is now.

The IntegTree Solution

  • At IntegTree we provide both training and consulting services.  We help you put in place “adequate procedures” to minimize exposure to the UK Bribery Act.  We review your Code of Conduct and policies to ensure you are in compliance with all laws and regulations, and to ensure that your anti-corruption policies are consistent with both the FCPA and the UK Bribery Act. 
  • We analyze your risks, and can help with due diligence assessment of your operations, those of your subsidiaries, and third parties with whom you do  or may do business.
  • We also train your workforce, including managers and contracting employees, on the UK Bribery Act.  We simplify the language of the Act to educate your workers on best practices, ensure “adequate procedures” are maintained, and encourage internal reporting of violations.     
  • As with all IntegTree training programs, we work with you to customize the training to that most relevant to you.  We can deliver both short training courses and a more in-depth training intervention.  Customized Online materials can also be developed to meet your specific, ongoing training needs.