Richard Alderman, Director of the Serious Fraud Office dropped another clue yesterday about what “adequate procedures” might mean under the 2010 Bribery Act.
The reference to checking tax calculations for evidence of bribery—as reported in today’s FT—seems to suggest that companies might need to scrutinise their own tax records from time to time for signs of corruption. This looks like a broad hint that this will be one element of best practice which companies will need to follow if they are to prove that they have “adequate procedures” in place to prevent bribery. Under the Act, a company needs to show it has adequate procedures to avoid corporate prosecution if a rogue individual from their company or an associated company pays a bribe.
Thanks for the clue, Richard. We are currently working with our members on this and other aspects of corporate behaviour to help ensure compliance with the legislation.
For further details on our work in this area please see our Responsible Business page.